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PensionRisk

Updated May 2026 · PBGC + DOL Form 5500

Moderate Risk Pension Plans

Plans with some funding challenges but generally manageable risk levels. May need attention but not in immediate danger.

53 pension plans currently sit in the moderate-risk tier — covering 12,416,868 active and retired participants with an average funding ratio of 73.4%. Risk is contained but not absent.

Moderate PBGC risk means enhanced monitoring without active intervention — the plan's funded status warrants attention but does not yet trigger formal rehabilitation requirements. 53 plans sit in this bucket.

PBGC risk classification applies primarily to private single-employer and multi-employer plans. Public-sector plans operate under state oversight rather than PBGC, so the risk signal there comes from state-level fiscal monitors instead of the federal scheme. For participants, the PBGC classification matters because it signals both the immediate intervention probability and the longer-term benefit-guarantee outlook. Each plan page below links to its full PBGC status and funding history.

What "Moderate Risk" Means in Practice

Moderate-risk plans sit near the national average. Funding ratios typically run 75%–90% with mixed trend signals. These plans are not in immediate stress but lack the cushion to absorb a major market shock or contribution holiday without slipping into the high-risk band. Most U.S. defined-benefit plans cluster in this range when measured at standard actuarial assumptions.

The 53 listed plans report a combined $823.4B in unfunded liability — the dollar gap between plan assets and the present value of accrued benefit obligations at each plan's assumed discount rate.

For ERISA-covered private and multiemployer plans, risk classifications draw from PBGC publications and from DOL Form 5500 Schedule SB or MB filings, which disclose the actuarial valuation, the assumed return rate, and any at-risk or Critical-status designation. For public plans, risk reads come from the Public Plans Database compilation of ACFR data, since public plans are not subject to PBGC.

None of this content is investment advice. Participants concerned about a specific plan should review the most recent Annual Funding Notice (mailed annually under ERISA Section 101(f)) and consult a fee-only fiduciary advisor before making any decision about a benefit election or rollover.

Plans at Moderate Risk

#Plan NameTypeStateParticipantsFunding RatioUnfunded GapGrade
1California Public Employees Retirement System (CalPERS)
State of California
publicCA2,050,00067.3%$230.0BC
2Teacher Retirement System of Texas (TRS)
State of Texas
publicTX1,730,00078.1%$54.0BB
3California State Teachers Retirement System (CalSTRS)
State of California
publicCA985,00072.9%$118.0BB
4Virginia Retirement System (VRS)
State of Virginia
publicVA740,00075.1%$28.8BB
5Arizona State Retirement System (ASRS)
State of Arizona
publicAZ588,00072.3%$17.6BB
6Indiana Public Retirement System (INPRS)
State of Indiana
publicIN425,00078.2%$10.3BB
7Georgia Teachers Retirement System (TRS)
State of Georgia
publicGA405,00077.4%$21.6BB
8Maryland State Retirement & Pension System
State of Maryland
publicMD398,00072.1%$23.6BB
9Minnesota Public Employees Retirement Association (PERA)
State of Minnesota
publicMN378,00079.1%$9.2BB
10Oregon Public Employees Retirement System (PERS)
State of Oregon
publicOR375,00077.3%$24.7BB
11NYC Employees Retirement System (NYCERS)
New York City
publicNY370,00076.8%$23.3BB
12Kansas Public Employees Retirement System (KPERS)
State of Kansas
publicKS328,00072.3%$9.5BB
13Employees Retirement System of Texas (ERS)
State of Texas
publicTX327,00070.1%$13.4BB
14NYC Teachers Retirement System (TRS)
New York City
publicNY225,00074.2%$32.0BB
15School Employees Retirement System of Ohio (SERS)
State of Ohio
publicOH218,00067.9%$7.7BB
16Nevada Public Employees Retirement System (PERS)
State of Nevada
publicNV218,00076.2%$15.7BB
17Minnesota Teachers Retirement Association (TRA)
State of Minnesota
publicMN195,00079.8%$7.1BB
18Los Angeles County Employees Retirement Association (LACERA)
Los Angeles County
publicCA186,00075.2%$24.2BB
19Alabama Teachers Retirement System (TRS)
State of Alabama
publicAL178,00068.2%$12.8BB
20Teachers Retirement System of Louisiana (TRSL)
State of Louisiana
publicLA172,00066.1%$11.0BC
21Oklahoma Teachers Retirement System
State of Oklahoma
publicOK162,00067.8%$8.6BB
22Georgia Employees Retirement System (ERS)
State of Georgia
publicGA138,00077.2%$5.3BB
23Alabama Employees Retirement System (ERS)
State of Alabama
publicAL132,00069.8%$6.7BB
24Missouri State Employees Retirement System (MOSERS)
State of Missouri
publicMO120,00072.2%$3.7BB
25Minnesota State Retirement System (MSRS)
State of Minnesota
publicMN112,00077.3%$4.3BB
26Arkansas Teacher Retirement System (ATRS)
State of Arkansas
publicAR112,00071.9%$7.2BB
27New Mexico Public Employees Retirement Association (PERA)
State of New Mexico
publicNM108,00067.9%$7.7BB
28Arkansas Public Employees Retirement System (APERS)
State of Arkansas
publicAR98,00074.8%$3.2BB
29Oklahoma Public Employees Retirement System (OPERS)
State of Oklahoma
publicOK88,00070.3%$4.3BB
30Lockheed Martin Corporation Retirement Plan
Lockheed Martin
corporateMD84,56478.8%$4.7BB
31New Hampshire Retirement System (NHRS)
State of New Hampshire
publicNH72,00065.1%$5.3BC
32Montana Public Employee Retirement Administration (MPERA)
State of Montana
publicMT65,00075.2%$4.1BB
33NYC Police Pension Fund
New York City
publicNY60,00078.3%$13.6BB
34West Virginia Public Employees Retirement System
State of West Virginia
publicWV60,00078.1%$1.7BB
35Ohio Police & Fire Pension Fund (OP&F)
State of Ohio
publicOH56,00073.8%$6.2BB
36Los Angeles City Employees Retirement System (LACERS)
City of Los Angeles
publicCA49,00075.8%$6.4BB
37Orange County Employees Retirement System (OCERS)
Orange County
publicCA46,00076.2%$6.4BB
38West Virginia Teachers Retirement System
State of West Virginia
publicWV45,00068.3%$2.7BB
39North Dakota Public Employees Retirement System (NDPERS)
State of North Dakota
publicND44,00068.3%$1.9BB
40Wyoming Retirement System (WRS)
State of Wyoming
publicWY38,00077.8%$2.3BB
41Alaska Public Employees Retirement System (PERS)
State of Alaska
publicAK38,00067.8%$3.4BB
42NYC Fire Department Pension Fund
New York City
publicNY28,00076.2%$5.5BB
43Contra Costa County Employees Retirement Association
Contra Costa County
publicCA23,00078.3%$2.8BB
44Vermont State Employees Retirement System
State of Vermont
publicVT22,00067.9%$1.1BB
45Denver Employees Retirement Plan
City of Denver
publicCO21,00079.2%$1.3BB
46San Diego City Employees Retirement System (SDCERS)
City of San Diego
publicCA20,50073.3%$3.7BB
47Detroit General Retirement System
City of Detroit
publicMI20,00071.8%$780.0MB
48National Electrical Benefit Fund (NEBF)
IBEW & NECA
multiemployerDC18,61974.3%$523.2MA
49Phoenix Employees Retirement System
City of Phoenix
publicAZ18,00068.1%$1.5BB
50San Jose Federated City Employees Retirement System
City of San Jose
publicCA12,00074.2%$1.5BB
51General Motors Hourly-Rate Employees Pension Plan
General Motors
corporateMI11,39577.1%$219.7MB
52General Motors Salaried Pension Plan
General Motors
corporateMI3,06171.5%$187.0MC
53International Brotherhood of Boilermakers National Pension Trust
Boilermakers Union
multiemployerKS72971.4%$55.9MB

How Risk Classifications Are Determined

For ERISA-covered private and multiemployer plans, classifications come from PBGC publications and from the at-risk and Critical-status designations disclosed on Schedule SB and Schedule MB of Form 5500. For public plans, classifications are derived from funding ratio and 3-year funding trend, since public plans are not subject to PBGC. The Pension Health Score weights PBGC risk at 20% of the composite, alongside funding ratio (50%) and trend (30%). Read the full methodology.

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Frequently Asked Questions

What does "Moderate Risk" mean for a pension plan?

Plans with some funding challenges but generally manageable risk levels. May need attention but not in immediate danger. Moderate-risk plans sit near the national average. Funding ratios typically run 75%–90% with mixed trend signals. These plans are not in immediate stress but lack the cushion to absorb a major market shock or contribution holiday without slipping into the high-risk band. Most U.S. defined-benefit plans cluster in this range when measured at standard actuarial assumptions.

How many pension plans are at moderate risk level?

PensionRisk currently classifies 53 pension plans at moderate risk. The top 53 are listed below by participant count and unfunded liability, covering 12,416,868 active and retired participants in aggregate.

What is the PBGC and how does it set risk classifications?

The Pension Benefit Guaranty Corporation is a federal agency that insures private-sector defined-benefit pensions. PBGC publishes a list of multiemployer plans in Critical or Critical-and-Declining status under PPA, and a separate framework for corporate single-employer plans designated as at-risk under ERISA Section 430(i). Plans funded below 80% are at-risk, and plans below 70% face stricter rules including amendment and lump-sum distribution restrictions. PBGC publications and the agency's annual report are available at pbgc.gov.

Are public pensions PBGC-rated?

No. Public pension plans — those sponsored by state, county, or municipal governments — are not subject to ERISA or PBGC. They have no federal risk classification. PensionRisk applies a low PBGC-risk default to public plans for the purpose of computing the Pension Health Score; the actual risk signal for public plans comes from funding ratio, 3-year trend, and the sponsor's contribution discipline as reported in each system's ACFR.

Where does the underlying data come from?

Risk classifications come from PBGC publications for ERISA-covered plans and from PensionRisk's composite scoring for public plans (low PBGC-risk default, with funding ratio and trend driving the overall risk read). Funding ratios come from DOL Form 5500 Schedule SB or MB and the Boston College Public Plans Database. The current dataset reflects filings available as of May 2026.

53 pension plans currently sit in the moderate-risk tier — covering 12,416,868 active and retired participants with an average funding ratio of 73.4%. Risk is contained but not absent.