Multiemployer Pension Reform Act (MPRA)
The Multiemployer Pension Reform Act of 2014 (MPRA) established a new process for multiemployer pension plans to propose a temporary or permanent reduction of pension benefits if the plan is projected to run out of money. Trustees of a multiemployer pension plan that is in critical and declining status, meaning it is projected to run out of money in less than 15 years, have the option to seek a reduction of benefit payments under the plan, if the Treasury Department determines that certain requirements are met. For the small subset of multiemployer plans facing insolvency, applying for benefit suspensions under MPRA was the last and only hope for keeping the plan operating indefinitely for the benefit of its participants. While MPRA benefit cuts can be painful to participants, benefits would still be higher than if the plan was taken over by the Pension Benefit Guaranty Corporation (PBGC), and even more uncertainty if the PBGC itself went insolvent.
The American Rescue Plan Act of 2021 (ARPA) established a special financial assistance program to enable eligible multiemployer plans to pay benefits without reduction for many years into the future. Importantly for plans that reduced benefits under MPRA, this law provides funds to reinstate previously suspended benefits ARPA also addresses the solvency of PBGC’s Multiemployer Insurance Program, which was projected to become insolvent in 2026.
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Guidance for Plans Following Receipt of Special Financial Assistance
- American Rescue Plan Act FAQs, PBGC, updated 7/19/23
- Annual Funding Notice Requirements for Multiemployer Pension Plans That Received SFA, Field Assistance Bulletin No. 2023-01, DOL, 4/25/23
- Statement Supporting PBGC Interim Final Rule, DOL, 4/25/23 (Supporting ARPA objective to restore benefits that were previously suspended under MPRA)
Special Financial Assistance Final Rule - Effective August 8, 2022
- How SFA Rules Impact Annual Funding Notice Requirements, International Foundation, 5/9/23
- Where We Are Now: SFA Under the American Rescue Plan Act, International Foundation, 3/28/23
- SFA Rule Adds Exception Process for Certain Withdrawal Liability Conditions [Press Release], PBGC, 1/25/23
- PBGC Special Financial Assistance “Lock-In” Application for Nonpriority Plans, International Foundation, 11/8/22
- PBGC Special Financial Assistance Final Rule: Permissible Investments, International Foundation, 10/25/22
- PBGC Releases Special Financial Assistance Final Rule, International Foundation, 7/8/22
- Special Financial Assistance Under the American Rescue Plan Act of 2021, Milliman, 7/25/22
- PBGC Issues Final Regulation for Multiemployer Plans Applying for SFA, Groom Law Group, 7/20/22
- PBGC Issues Guidance on New SFA Program for Troubled Multiemployer Pension Plans, Proskauer, 7/15/22
- Multiemployer Pension Rescue Tracker, House Education & Labor Committee (regularly updated)
Special Financial Assistance Interim Final Rule - Released July 9, 2021
- Five Key Points to Know About PBGC Special Financial Assistance, International Foundation, 8/30/21
- Special Financial Assistance: Filing and Application Tips From PBGC Staff, International Foundation, 8/12/21
- PBGC Implements Special Financial Assistance Program for Financially Troubled Multiemployer Pension Plans, International Foundation, 7/15/21
American Rescue Plan Act - Enacted March 10, 2021
- The American Rescue Plan Act: New Relief for Multiemployer Pension Plans, International Foundation, May 2021
- What the American Rescue Plan Act Means for Financially Troubled Multiemployer Pension Plans, International Foundation, 3/10/21
- Three Key Takeaways: What ARPA Means for Green Zone Pension Plans, International Foundation, 4/29/21
Status of Applications to Reduce Benefits Under MPRA
Applications for Benefit Suspension, Department of Treasury (2021 and earlier)
Foundation Resources
- Proposed Multiemployer Pension Recapitalization and Reform Plan, International Foundation, 11/26/19
- Navigating a Benefit Suspension Application Under MPRA, Benefits Magazine, May 2019
- Multiemployer Pension Solvency Discussions: What’s Next?, International Foundation, 11/29/18
- Confronting and Surviving Insolvency: A Guide for Multiemployer Pension Plans, Benefits Magazine, October 2017
- A Balancing Act: Deciding Whether to Pursue Benefit Reductions Under MPRA, Benefits Magazine, April 2016
- MPRA Aims to Strengthen PBGC, Benefits Magazine, February 2016
- Can a Merger Save Your Pension Plan?, Benefits Magazine, October 2015
- PPA Paradoxes Eliminated: MPRA Offers Technical Corrections...and More, Benefits Magazine, August 2015
- MPRA Guidance-What Does It Mean?, International Foundation blog, 7/13/15
- Finding Goldilocks: The Retiree Representative Under MPRA, Benefits Magazine, June 2015
- Multiemployer Pension Plan Reform: How Will the New Rules Impact Employers and Employees?, Benefits Magazine, April 2015
- What the Cromnibus Law Means for Multiemployer Pension Plans, International Foundation, 12/15/14
Analysis & Whitepapers
- Selection of Actuarial Assumptions for Multiemployer Plans, American Academy of Actuaries, July 2020
- Multiemployer Pension Plan Reform Policy Issues: Active Multiemployer Plan Participants Face Higher Contributions and Lower Benefit Levels as Funding Challenges Mount and are Left Unaddressed by Congress, Horizon Actuarial Services, MCAA and United Association, June 2019
- Pensionomics 2018: Measuring the Economic Impact of Multiemployer DB Pension Expenditures, National Institute on Retirement Security, January 2019
- History and Structure of the Multiemployer Pension System, American Academy of Actuaries, 5/18/18
- Data on Multiemployer Defined Benefit (DB) Pension Plans, Congressional Research Service, 5/1/18
- U.S. Chamber, National Coordinating Committee for Multiemployer Plans Release Principles for Multiemployer Pension Reform, NCCMP, 3/14/18
- The Multiemployer Pension Plan Crisis: The History, Legislation, and What's Next?, U.S. Chamber of Commerce, December 2017
- Multiemployer Plans: Their Current Circumstances in Historical Context, DOL EBSA & Impaq International, September 2017
- Honoring the PBGC Guarantee for Multiemployer Plans Requires Difficult Choices, American Academy of Actuaries, 10/20/16
- Solutions Not Bailouts, Retirement Security Review Commission, National Coordinating Committee for Multiemployer Plans (NCCMP), February 2013