What pointers does the SHPS Valuation provide for employers in SHAPS
In early October the results of the Social Housing Pension Scheme (‘SHPS’) actuarial valuation at 30 September 2017 were published and are available here. I’ve provided a full commentary on the impact and options for employers in the scheme here.
Given that the SHPS results are 12 months ahead of those in the Scottish Housing Associations Pension Scheme (‘SHAPS’) which are due at 30 September 2018 I wanted to consider if the results would provide a good barometer for what Scottish RSL’s might expect when they get their results next year.
The SHAPS scheme is much smaller than SHPS with a smaller number of employers but the two schemes do share many similarities in terms of employer covenant, trusteeship and investment methodology so the results should certainly identify trends.
If we start with the actuarial valuation assumptions for SHPS and SHAPS these are shown in the table below.
30 September 2014
30 September 2015
30 September 2017
||RPI – 3.1%
CPI – 2.2%
|RPI – 3.1%
CPI – 2.2%
|RPI Curve (3.4%)
RPI Curve less 0.9% (2.5%)
Gilt Curve plus 2.4% (4.2%)
Gilt Curve plus 0.45% (2.25%)
|Pensionable earnings growth (annual)
You can immediately see that the SHAPS assumptions at 30 September 2015 are very similar to those adopted by SHPS in 2014 with only a slight reduction in the discount rate pre and post retirement from 5.9% and 3.3% to 5.7% and 3.1% respectively and a salary increase assumption of 3.7% versus 4.2% to reflect different market conditions. The inflation assumptions were identical.
The changes to the SHPS valuation assumptions reflects changes in market conditions and a strengthening of the assumptions being used and these changes accounted for almost all of the identified deficit.
In a commentary I wrote on the 2015 SHAPS Valuation results I expressed some surprise/shock at the funding assumptions used. At a time when all the market indices were indicating a reduction in gilt yields the trustees decided to increase the discount rate used pre retirement from 5.3% p.a. in 2012 to 5.7% p.a. in 2015. This was apparently to reflect a strengthening in employer covenant. This decision had the effect of reducing the scheme liabilities and therefore the on-going deficit by around £100m. This would have been positive news for the employers but was this improvement real or some funding smoke and mirrors. Comparing the on-going deficit in 2012 of £304m to a cessation deficit of £732m compared to an on-going deficit of £198m in 2015 and a cessation deficit of £937m highlighted the change in funding prudence. My expressed concern was that this approach may result in additional future prudence and therefore increased future deficit contributions being required.
Given the similarities in the covenant strength and investment / funding approach across both schemes it does not seem unreasonable to assume that a similar methodology will be applied to the SHAPS valuation, though this would be something of a backtrack from the 2015 position.
If the trustees are adopting the same commitment “to both security and affordability” how can they not apply a consistent basis which would result in a materially higher deficit amount? If they do employers may reasonably question the approach taken in 2015.
We do not have the exact details of the SHPS change but from the information provided it looks like the discount rate has been reduced by 0.6% p.a. which alone could increase liabilities by around 5%. There may also be a further increase in liabilities to move the SHAPS assumptions in line with SHPS which could further increase the scheme deficit. Given that, as an example, the pre-retirement discount rate assumption in the SHPS valuation reduced from 5.9% to 4.2% this could be very material.
Like SHPS, SHAPS has deficit contributions based on proportion of salary and proportion of liabilities and a move to simplify contributions similar to SHPS could be attractive to the scheme. Whilst in my view the setting of contributions based purely on share of liabilities is a fairer distribution of cost it will mean that that there are some winners and losers in terms of contributions with potentially small numbers of employers seeing very material increases as a result of any change.
What would also be concerning for employers would be how the conversion from the existing funding basis with contributions reducing over the next few years to a level basis costed as a share of liabilities, similar to SHPS, would result in very material increases in future contributions and a linked increase in FRS102 accounting deficits just at the point where the scheme is promoting a move to a full FRS102 disclosure basis.
In terms of future service contributions the position may be less dramatic in SHAPS than in SHPS. Contributions increased materially at the 2015 SHAPS valuation to 27.1% p.a. for Final Salary 60th benefits and 25.8% p.a. for CARE 60th benefits. Both these figures include 0.7% p.a. death-in-service costs and reduced by 2% where employers offer DB to new entrants. These contributions are in my view more reflective of the costs of buying benefits and compare reasonably with the new SHPS rates. I would however still expect some increase to future service rates in SHAPS to reflect current market conditions, maturing scheme membership and costs being shared over a smaller membership population.
Given the more the material re-distribution of members in SHAPS away from DB I suspect we could also see an increase in on-going scheme expenses similar to that in SHPS.
Based on the above therefore I think it’s wholly reasonable to assume that SHAPS employers can expect similar bad news when they receive their results in 2019 as SHPS employers are currently dealing with. There could be something of a ‘triple whammy’ with negative movements in market conditions, a strengthening of valuation assumptions and increases in operational costs.
With DB membership numbers continuing to fall (now only around 1,000 compared to the 3,500 participating in 2012), only around 1/3rd of employers open to new DB members and huge increases in DC membership the scheme shape is changing. Any further increases in SHAPS contributions is likely to further hasten exits from DB and there must come a point where there will need to be a serious discussion about the future of the DB section of the scheme. Employers may also be once again questioning the approach adopted in 2015.