PRB Opens Public Comment on Proposed FSRP Rule Clarifications — Arriving at a Moment of Historic Strength for Texas Pensions
The Texas Pension Review Board has opened a 30‑day public comment period on proposed amendments to the rules governing Funding Soundness Restoration Plans.
These updates aim to clarify statutory requirements, improve compliance, and streamline reporting for systems and their sponsoring entities. TEXPERS encourages its members to review the proposals closely and to work with TEXPERS if they want help in formulating concerns. Responses are due no later than September 7.
The PRB’s request for public input comes at a notable time: Texas currently has zero active FSRPs statewide, a historic milestone announced at the PRB’s July 23 meeting. As PRB Actuary David Fee noted, “My notes say to pause for thunderous applause,” and PRB Member Christopher Zook responded, “Amen, way to go!”
What the Proposed Rule Changes Would Do
The PRB recently issued a Plain Language Summary, which summarized the proposed amendments as follows:
- Clarify applicability and exemptions for the FSRP requirement, including recognition of previously authorized voluntary FSRPs.
- Require systems to provide the PRB a copy of the notice of inadequate funding arrangement within 30 days of sending it to members.
- Remove subjective language related to allowable variation from established corridors.
- Allow early submission of an FSRP if the PRB determines the plan meets statutory funding‑period requirements.
- Require progress updates using a PRB‑created form, aligning rule language with current statute and removing outdated provisions.
- Make minor technical and clarifying corrections throughout.
Public comments may be submitted to [email protected], with the rule name and number in the subject line. The proposed rules may be reviewed in their entirety here in the Texas Register.
Comments must be received by Sept. 7, 2026, to receive staff consideration before being presented to the Board.
Why This Matters Now: Texas Systems Are Stronger Than Ever
The PRB’s request for feedback arrives during a period of unprecedented statewide improvement in pension funding.
As highlighted in a previous blog post, no Texas public retirement system is currently subject to an active FSRP. This is the first time this has ever happened since the Legislature created FSRPs in 2015. Systems such as Dallas Police & Fire, Garland Fire, San Benito Fire, and Harlingen Fire have all been removed from the list since February 2026. Here are the major achievements noted at the last meeting:
- 44 systems now have funding periods under 15 years, double the number from 2020.
- Systems with funding periods over 30 years have dropped from 35 to just 10.
- Modernization of actuarial assumptions is accelerating, with many TLFFRA and municipal systems lowering return expectations.
- Sponsor engagement is strengthening, especially following PRB’s March 2026 letter encouraging ADCs and Social Security participation.
This statewide progress underscores why Texas pension plans should pay close attention to refinements of the FSRP rules. They should reflect today’s stronger landscape while ensuring clarity for systems that may face future challenges.
How Trustees and Members Can Participate
The PRB encourages Trustees, sponsoring entities, members, and association partners to review the proposed changes and submit comments.
Clear, constructive feedback helps ensure the rules remain practical, transparent, and aligned with the realities of pension governance.
TEXPERS Communications professional can assist in delivering comments to the PRB.
“With Texas systems marking a historic clean slate on FSRPs, now is the perfect time to help shape the next generation of PRB rules,” said Art Alfaro, executive director of TEXPERS. “We encourage all members and trustees to review the proposed updates and share their perspectives.”
About the Author: Joe Gimenez is a public relations specialist in pension fund communications. He assists TEXPERS and several Texas retirement systems in public affairs.
AI Transparency Disclosure: Artificial intelligence was used to generate the banner art for the blog post.


