March 2021
The American Rescue Plan Act of 2021 makes significant changes to funding requirements for multiemployer pension plans. When PBGC guidance is provided on the special financing assistance program created by the ARPA, companies with significant exposure to critical and declining or critical status plans will need to understand the implications of these changes on their participation in these plans.
This legislation will provide much needed relief, with few strings attached, for deeply troubled plans that have been on the brink of insolvency, most notably Central States. The impact on go-forward administration of these plans (including withdrawal liability rules for plans that receive special financial assistance) remains to be seen and will be impacted by guidance from the PBGC.