Funding Soundness Restoration Plan

Funding Soundness Restoration Plans (FSRPs) are developed by Texas public retirement systems and their sponsors to improve the funding status of financially distressed plans. The requirement was established by the Texas Legislature in 2015 and updated in 2021.

There are different types of FSRPs. The type of FSRP a retirement system prepares depends primarily on when the system triggered the requirement:

The governing body of the public retirement system and the associated governmental entity (sponsor) is required to formulate a funding soundness restoration plan (FSRP) if it meets any of the triggering criteria:

    • The system’s actuarial valuation shows that the system’s funding period has exceeded 30 years for three consecutive annual actuarial valuations.
    • The system’s actuarial valuation shows that the system’s funding period has exceeded 30 years for two consecutive actuarial valuations in the case of a system that conducts the valuations every two or three years.
    • Only applicable after Sept. 1, 2025:
      • The system’s funding period has exceeded 40 years for one actuarial valuation.
      • The system’s funding period is between 30 and 40 years and the funded ratio is less than 65 percent for one actuarial valuation.

An FSRP is due two years from the valuation date of the actuarial valuation that triggered the requirement to formulate the FSRP. The agreed-to FSRP must be received by the PRB by the 31st day after the day the plan is agreed to.

In most cases, if a system triggers a second FSRP within 10 years of the due date of the previous FSRP, the system is required to complete an R-FSRP instead of an FSRP.

 

Systems with legacy FSRPs and other systems that qualify for the Revised FSRP Exemption (see description below) would complete an FSRP rather than an R-FSRP.

PRB rules allow a retirement system to prepare a V-FSRP without first becoming subject to the FSRP requirement. A V-FSRP must follow most of the submission requirements outlined in statute and rules to be accepted.

There are advantages to preparing a V-FSRP:

  • A system preparing a V-FSRP does not need to provide progress updates to the PRB.
  • An FSRP formulated on or before September 1, 2025, is eligible to qualify for the Revised FSRP Exemption. Under this exemption, a system that triggers an FSRP would complete a standard FSRP instead of an R-FSRP. This means the system would not need to include the additional components required for an R-FSRP.
  • It would allow the system and sponsor to be proactive when addressing challenges the retirement system is facing. Funding problems typically compound, so any delays in making corrections can make shortfalls worse. If the system triggers an FSRP while preparing a V-FSRP, they will already have a head start in making a plan.

A few systems remain compliant with an FSRP submitted prior to September 1, 2021 under previous law. These systems can continue to operate under the L-FSRP through their 10-year target date on or before 2031.

The PRB has created a variety of graphics and educational materials to help system trustees and administrators understand the FSRP requirements. Click here to view the FSRP educational materials.

FSRP Submission Form

When submitting an FSRP, please complete and submit the Funding Soundness Restoration Plan Coversheet form along with the required materials. Click here to access the form.

FSRP Report

PRB Staff provides its board with periodic updates on systems that have submitted FSRPs. View the recent reports below. Older reports may be found in board meeting packets.

September 2024 | July 2024 | March 2024

FSRP: Overview, Implementation, and Case Studies

In September 2024, The PRB published a study on the FSRP requirement. The intent of this study is to explain the FSRP requirement and its evolution, evaluate the impact of the FSRP requirement overall, and to assist systems and their sponsors who have triggered, or may be at risk of triggering, the requirement.

View Study

FSRP Statute, Rules, and PRB Policy

The statutory requirements for Funding Soundness Restoration Plans (FSRPs) can be found in Sections 802.2015 or 802.2016 of the Texas Government Code.

Rules related to preparation, submission, and compliance with FSRPs can be found in 40 T.A.C. Chapter 610.

The PRB’s “Policy for Promoting Compliance with Funding Soundness Restoration Plans Requirements,” outlines action the PRB or staff will take, including actions if an FSRP is missing or noncompliant.

FSRP Progress Updates

Systems that are subject to an FSRP are required to provide periodic updates on their progress while preparing the plan.

  • First Update: This update must:
    • Include a projected timeline for enactment of the plan.
    • Identify the action that various entities must take to improve or enact the plan (ex: a vote of the membership if required by governing statute).
    • Be submitted within one year of the triggering valuation date.

Please note this is a minimum requirement. Your update may include additional information, beyond the minimum requirement.

  • Future updates: Each subsequent update should
    • Include a draft of the FSRP.
    • Contain updated information showing movement toward finishing the FSRP.
    • Be submitted every six months after a previous progress update until the FSRP is submitted.

For example, a system with a triggering valuation date of Dec. 31, 2024, would have the first update due by Dec. 31, 2025. The second update would be due by June 30, 2026, and the FSRP would need to be submitted by Dec. 31, 2026.

FSRP Submission vs. Completion

There are different stages of finishing an FSRP.
  • Submission: This is when the PRB receives your required materials:
    • completed FSRP Submission Form (Funding Soundness Restoration Plan Coversheet)
    • documentation the FSRP has been adopted by both the system and the sponsor at an open meeting
    • other materials necessary to show the system’s funding period is within 30 years

Deadline: FSRPs for systems that triggered the requirement prior to Sept. 1, 2023, must be submitted no later than Sept. 1, 2025. All other FSRPs must be submitted within two years of the valuation date of the actuarial valuation (AV) that triggered the FSRP.

  • Completion: This is when the PRB receives
    • an AV or other analysis showing the asset-liability projection for the system between the triggering valuation date and the date the system is expected to reach full funding
    • description of assumptions and methods used to perform the analysis.

The PRB staff actuary or board actuary will determine if this analysis is consistent with actuarial standards of practice.

  • If materials are not sufficient to fulfill the requirements, the PRB will provide an explanation of additional materials necessary to be in compliance with the requirements.

Standard FSRPs vs R-FSRPs

  • The maximum allowable funding period for an R-FSRP is 25 years rather than 30 years for a standard FSRP.
  • Some components are required for R-FSRPs while they are optional for an FSRP:
    • an actuarially determined contribution (ADC) structure
    • automatic risk-sharing mechanisms, which are defined as changes to plan provisions upon meeting or exceeding certain preestablished criteria without needing additional approval at the time of the change
    • at least one of the automatic risk-sharing mechanisms must be an adjustable benefit or contribution mechanism

Revised FSRP Exemption

Some systems may qualify for the Revised FSRP Exemption described in statute. If a qualified system triggered a new FSRP during the 10-year eligibility period for an FSRP, it would complete a standard FSRP rather than an R-FSRP.

To qualify for the exemption, a system must have a funding period between 30 and 40 years and meet one of two additional conditions:

  • Adhering to an FSRP formulated on or before Sept. 1, 2025. (Includes both L-FSRPs and FSRPs submitted between Sept. 1, 2021, and Sept. 1, 2025.)
  • Using or ultimately will use an ADC contribution structure.

Compliance corridors are used to determine if a system is adhering to an FSRP to qualify for the exemption. Compliance corridors have a baseline and a corridor of variation from that baseline that narrows towards the end of the exemption period. As long as the system’s funding period or funded ratio remains within the corridor, it would be considered adherent.

There are two types of compliance corridors for FSRPs submitted between Sept. 1, 2021, and Sept. 1, 2025:

  • Funding period corridors have a baseline of 30 years.
  • Funded ratio corridors are based on the asset-liability projection submitted as part of the required AV or separate analysis needed to complete an FSRP.

You can find the sizes of these corridors around the baseline in the tables here.

Systems with L-FSRPs have the option to establish compliance corridors for the purpose of qualifying for the exemption. To do this, the system would need to submit its own asset-liability projection, similar to what is required for systems completing FSRPs under current statute. If the L-FSRP system decides not to submit a projection, the system would only have a funding period corridor with a baseline of a one-year-per-year reduction while the system’s funding period remains above 40 years. If the system’s funding period is less than 40 years, then the baseline would remain at 40 years. You can find the sizes of these corridors around the baseline in the tables here.

FSRP News

In August 2022, the PRB gave a presentation covering FSRPs at the 2022 Annual TEXPERS Summer Educational Forum. Click here to view the presentation.