SFA Bailout Timeline

For those wondering when payments under the PBGC Special Financial Assistance program will be coming, the International Foundation of Employee Benefit Plans blog has some guidance.

The Pension Benefit Guaranty Corporation (PBGC) and Treasury officials have delivered a new briefing on the special financial assistance (SFA) program for financially troubled multiemployer plans under the American Rescue Plan Act of 2021 (ARPA). During the briefing on July 22, 2021, PBGC officials walked through the e-filing process, application instructions, assumption changes and what to expect after submitting the application. A recording and slides of the briefing are available here.

During the 120 Day Review

Ross Marcelin urged plans to be on the lookout for confirmation of receipt within two weeks. Be aware that PBGC staff may reach out to filers with clarifying questions or any issues with the uploaded documents within 120 days of the filing date. During the 120-day window, plans must notify PBGC about any facts or data submitted in the application that are no longer accurate. By day 120, PBGC will make a determination to approve or deny the SFA application.

Payment of SFA

An approved plan should expect the SFA payment to be made within 60 days of approval. The automated clearing house (ACH) vendor or miscellaneous payment enrollment form is required when submitting the application. The form is used to enable the plan to receive an electronic transfer of funds. PBGC will use the ACH system for amounts up to $100 million. PBGC will use the Fedwire system for transferring amounts over $100 million. Prior to the transfer, plans should get in touch with their bank to ensure that there won’t be any difficulties or obstacles for a very large transfer. Confirm the bank’s routing number and any other information necessary for a Fedwire transfer.

Those dates: