Making Sense of Pensions

John Wilson

The 2020 Annual Funding Statement (AFS) from The Pensions Regulator (TPR) was published today (Thursday, 30 April) and is particularly relevant to schemes with valuation dates between 22 September 2019 and 21 September 2020 (so-called Tranche 15, or T15 valuations), as well as schemes undergoing significant changes that require a review of their funding and risk strategies.

The AFS sets out specific guidance on how to approach the valuation under current conditions, what TPR expect from trustees and employers, and what they can expect from TPR. TPR appreciate these are very “challenging times”. However, they expect all T15 valuations to fully incorporate the principles in the current DB code of practice and associated guidance.

The messaging builds on TPR’s Covid-19 guidance, repeating it in parts. The overarching theme is that, more than ever, trustees and employers need to work collaboratively.

The AFS contains some practical guidance on some scheme specific issues:

  • post valuation experience
  • changing valuation effective date
  • calculating technical provisions
  • recovery plan length
  • treatment of shareholders

As with the 2019 Statement, the 2020 AFS includes a helpful table setting out key risks and actions for employers and trustees.

We welcome the publication of the latest AFS which, understandably was issued a bit later than in previous years.

Whilst, for many pension schemes, there is understandably considerable focus on the short term, the longer term and, in particular, getting back on course to longer-term objectives, remains key. Many of the aspects previously outlined in TPR’s scheme funding consultation, such as the increasing importance on the role scheme maturity has to play and the “Fast Track and Bespoke” approaches, are still expected to come into force (albeit some of the parameters may necessarily have to change to allow for different market conditions).

In the meantime, TPR continue to expect trustees to focus on the integrated management of three broad areas of risk: the ability of the employer to support the scheme, the investment risks, and the scheme’s funding plans.

Brendan McLean

Diversified Growth Funds (DGF) are an easy way for investors to access a broad range of asset classes through one fund – ranging from equities and real estate to emerging market bonds. This diversification provides investors with exposure to various return drivers which can improve risk adjusted returns over the long term.

DGFs also come in a range of different styles, from highly dynamic absolute return funds to passive multi-asset funds. Within defined benefit pension schemes, DGFs are often sold as providing equity-like returns with lower volatility over the long term.

In recent years, DGFs have not lived up to this aforementioned return promise. This is primarily due to the fact that equities have seen huge increases and many DGFs have not kept up the pace of positive returns. However, investors see DGFs as more than just a vehicle for high returns, as they like to believe that their DGF will be better able to control risks and protect capital when markets crash, as they did in Q1 2020 or Q4 2018.

This was proved true over Q1 2020, when the average DGF return was -11% with global equities in pound sterling posting -16%. Absolute return type DGFs were better able to preserve capital and on average were only down 2% over the quarter. This is a good result, but it is expected due to their low beta allocation. The lack of protection from some DGFs during Q1 is due to the broad market selloffs with almost every asset declining in value; even more defensive assets such as investment grade corporate bonds declined. However, in Q4 2018 global equities declined -11% while the average DGF return was -5%, demonstrating that DGFs can protect on the downside.

The range of returns for DGFs is broad. While the average performance has been below expectations, they can still offer investors access to a range of diversified assets which is important for long-term diversification and returns.

Andrew Kerrin

For longer than we care to remember, our quarterly reports have seemed to focus on Brexit, or the lack of progress on pensions policies as a result of Brexit.  How distant those times now feel.  Yet, despite these even more uncertain times we find ourselves in, it is important to remember that at the end of the Covid-19 pandemic – and there will be an end – there will still be pension schemes, members, taxes, regulations and investments.  So, let us continue to look forward, continue to plan, continue to take action, and continue to influence those things that we can control.

Spence have summarised the main issues across our industry in this report, highlighting any actions that trustees and sponsors may need to take.  Clearly there is a focus on the impact Covid-19 is having on pension schemes, with articles addressing the latest guidance for trustees from the Pension Regulator and the investment market’s reaction.

Beyond the pandemic, the report also looks to other important matters, such as the progress of the Pensions Bill through the legislative process, the latest on the goliath GMP Equalisation issue and a summary of the Chancellor’s latest Budget, to name a few.

As always, we hope that this quarterly report can be of assistance and makes your lives that little bit easier, in these, the strangest of times. From everyone at Spence, stay safe and enjoy the read.

Click on the image on the right or this link to download.

Hugh Nolan

Pensions aren’t anyway near the main concern for most people at the moment, with the industry having proved pretty robust in the face of a global pandemic that can only be described as unprecedented. A lot of schemes had investment strategies in place that have largely mitigated the impacts of incredible volatility in markets and stocks that have fallen by over a third. Administrators have managed to keep paying pensioners reliably and promptly every month. Even the quasi-Governmental Regulator has responded positively to the situation, with a pragmatic and sensible approach that recognises the difficulties faced by many sponsoring employers and allows even more flexibility than usual.

But there is often a sting in the tail for pension schemes. Some schemes had deliberately adopted a policy of investing in growth assets like equities as their only hope of removing sizeable deficits. Sponsoring employers who had been struggling to meet the rising financial demands of their schemes over the years had to rely on investment returns to remove this millstone from their necks. Such schemes may have seen material falls in their funding levels that make a difficult situation seem completely impossible now.

My message to these schemes is simple. Don’t give up hope! Although nothing can be absolutely guaranteed, I am confident that markets will eventually recover most of their losses from the last couple of months. I’m sure there will have been a real hit from the pandemic in the final analysis and GDP in Q2 will be absolutely dire but current predictions are that the economy can rebound strongly later in the year. It took a couple of years for normal service to be resumed after the credit crunch and could take even longer after the virus crisis. However, there is every chance that we will get back to normality soon enough for most pension schemes to get through to the other side safely, even in very challenging circumstances.

My colleague Simon Cohen, our Head of Investment Consulting, has obviously been watching market developments closely and continually reminds me not to panic about the falls we have seen. Pension scheme funding is a long-term venture and the extreme volatility we have seen recently is just a specific example of what we always knew could (and probably would) happen from time to time. Actuarial valuations can allow for an expected bounce in the markets at some point and longer recovery periods can be agreed where needed. Investment strategies can implement trigger points to derisk portfolios when market opportunities present themselves. Members can be reassured that their pensions are well protected, with funds held separate from the employer, with companies still committed to funding the schemes and with the PPF lifeboat in the background. Trustees can be supported and helped to keep making the decisions that are best for the schemes, however difficult those decisions may seem just at the moment.

Some people may wish they’d taken more control of their pension schemes before the pandemic hit us. It’s never too late to take positive action though and there are still ways to plan for the future with a degree of optimism. As they say, the best time to plant a tree is 20 years ago and the second best time to plant one is right now!

Stay safe everyone and we’ll see you on the other side.

David Davison

Finally at the end of February 2020 the results were published on the consultation on LGPS Reform for England & Wales, which ended 31 July 2019, and it’s a bit of a mixed bag.

Valuation Cycle

It is proposed to move the local fund valuation cycle from 3 years to 4 years to link with the Government scheme valuation. With this change it is proposed to provide funds with the power to undertake interim valuation and a widening of the power to amend employers’ contribution rates. What unfortunately has not been proposed is a strengthening of the communication requirements on Funds to ensure that admitted bodies are aware of their funding position more regularly over this lengthened period.

Dealing with ‘Tier 3’ employers

In terms of seeking to help funds provide additional options for employers looking to exit the response states “Current regulations require that when the last active member of an employer leaves the scheme, the employer must pay a lump sum exit payment calculated on a full buy-out basis.” This is fundamentally incorrect and is a misunderstanding also commonly held by LGPS Funds. Regulation 64 specifies that Funds must obtain “an actuarial valuation at the exit date”. It neither specifies that this must be done on a buy-out basis, or even that when carried out that it has to be enforced. It is the Funds, and their actuarial advisers, who chose to enforce this exit on a buy-out type basis but it is not actually stipulated.

The response makes the proposal “to introduce ‘deferred employer’ status that would allow funds to defer the triggering of an exit payment for certain employers who have a sufficiently strong covenant. Whilst this arrangement remains in place, deferred employers would continue to pay contributions to the fund on an on-going basis.” Whilst at a high level the proposal is welcome it is deficient in a number of key areas:-

  • As part of our response to the consultation we highlighted specific experience of the introduction of similar provisions in Scottish LGPS in 2018. The revised Regulations were effectively ignored by Funds and has resulted in SPPA having to issue further consultation to see how the changes could be better implemented. The proposals made effectively replicate the Scottish wording without making any attempt to look to learn from their adverse experience.
  • Helpfully the response does recognise that “some smaller and less financially robust employers are finding the current exit payment in LGPS onerous” and that “rather than protecting the interests of members, it may mean employers continue to accrue liabilities that they cannot afford.” It can also mean they are “driven out of business.” This is certainly becoming a much more common occurrence and is likely to continue apace over months and years as admission bodies closed to new entrants gradually reach a point where they have no active members.

However, worryingly, the response then does not specifically deal with this referring to employers with a “sufficiently strong covenant”. How would this be defined? What would happen for those employers who do not meet this classification? The response wholly ignores that employers with a weak covenant only option is to continue to accrue further liabilities without a solution which is neither in their interests, the Fund as a whole and other employers in the Fund.

There continues to be no recognition of the risk of future accrual and the strain that puts on Funds and other employers and that there needs to be compromise for weaker covenants to reach an amicable solution.

  • There is a proposal that consideration is given to whether a maximum funding time limit of perhaps 3 years is considered. This is frankly ridiculous as the vast majority would struggle to pay cessation debts over even a 10 year term and much longer repayment terms need to be considered. For example, in Scotland, Strathclyde Pension Fund and Lothian Pension Fund are considering terms of up to 20 years. I would be interested to know what specific research has been carried out to consider if 3 years is affordable? None I suspect.
  • There is little recognition that S75 deferred status being used (or more rather not being used) in private sector multi-employer schemes is very different to what is likely to be needed on LGPS schemes as the background is completely different. The overall covenant for LGPS schemes is much stronger as more employers have public sector backing and the distribution of liabilities much more widely distributed with small charities representing a tiny fraction of overall liabilities and therefore small changes in deficit amounts making a negligible impact on the overall Fund value at risk. Most importantly also it is much less likely that LGPS will ever close to future accrual so being able to fund over a long period of time is much more palatable.
  • The issue of legacy liabilities which has seen admission bodies assume material amounts of historic benefits for ex public sector staff has been completely ignored.
  • The seemingly endless round of consultation on ‘Tier 3’ employers looks to continue as the SAB have commissioned AON to look at funding, legal and administrative issues. Surely after all this time there can’t be key individuals within Funds who don’t understand the issues and options. But no, lets rehash them all again with a view to the SAB making some recommendations to the Secretary of State later in the year.  A bit more fiddling while Rome burns!

Thankfully there are signs that some Funds are adopting a more pro-active approach even ahead of Regulatory change recognising that they need to do so in order to better deal with the issues. Unfortunately not all are quite so enlightened, choosing to wait for ‘chapter & verse’ when the consultation already confirms that the Ministry is not intending “to legislate for every aspect” but to provide a more flexible framework lead by Funds.

I can only hope we’re finally nearing the end of the ‘consultation’ and will soon move into something that looks more like implementation as demand is already high and only likely to increase.

Brendan McLean

The Retail Price Index (RPI) plays a significant role on both the asset and liability side of a pension scheme and any changes to the Index will have a far-reaching impact. Therefore, trustees need to take note of the recently proposed reforms to RPI.

What are the reforms?

In September last year, Sajid Javid, then Chancellor of the Exchequer, confirmed a public consultation would be held on the implementation of the UK Statistics Authority’s proposed reforms to RPI, with a specific focus on aligning it to the Consumer Price Index including Housing costs (“CPIH”).

These changes are proposed to take effect from 2030, however, to be considered as part of the public consultation, this date could be brought forward to 2025.

What impact will this have on pension schemes?

The impact of the reforms relates to the fact that the method of calculation is different for RPI and CPIH, which results in CPIH being lower by approximately 1% on average (this is sometimes referred to as the “formula effect” or “wedge”). This means that any instrument that has payments with a linkage to RPI, index-linked gilts for example, will see a reduction in those payments, thereby reducing the value of the instrument.

An individual’s pension or annuity, where payment increases are linked to RPI, would also see a reduction in the future expected cash flows.

Pension schemes will see the following effects:

  • If a scheme has RPI linked benefits, the total liability of the scheme can be expected to reduce.
  • Where schemes have hedged CPI linked liabilities using RPI linked assets, a loss can be expected (it is not uncommon for CPI linked liabilities to be hedged using RPI linked assets due to the fact that CPI linked assets are much less common).

The net position will be different for each individual scheme – action can be taken now to reduce the risk/impact of the proposed reforms, though the markets already seem to be pricing in some of the expected effects.

Further developments

There are many aspects of the reforms which are still undecided, and, as a result, leave the potential impact uncertain:

  • Possible compensation to those holding index-linked gilts (Insight Investment has estimated the potential loss to gilt investors at around £90 billion).
  • The date at which the reforms will be implemented.
  • What other related indices will be affected.

Once the exact nature of the reforms is finalised, the impact will be easier to assess. However, given the length of time until implementation, there is scope for further changes. Trustees and other affected parties should keep updated on developments and maintain a dialogue with their investment consultant to ensure the correct measures are put in place.

Meanwhile, schemes should at least be aware of any mismatch on assets intended to hedge inflation risk and trustees should satisfy themselves that they remain comfortable with the overall risk profile of their investment strategy.

David Davison

With most charities in LGPS having to disclose their pension funding position in their accounts at 31 March 2020, the recent turmoil in the markets is likely to be causing concern, particularly for those with limited balance sheet surplus. 

The FTSE 100 has fallen by over 30% since March 2019. While this does not directly reflect the impact on individual funds it is a good proxy for the change in growth assets over the year.

A ‘flight to safety’ will have increased the value of government bonds.  However, a widening of credit spreads will have reduced the value of corporate bonds. 

Overall, depending on the investment strategy employed by the fund, asset values may be down with Funds with very little hedging likely to see a significant fall in asset values.

The deficit recorded in your accounts also depends on the value placed on your liabilities, and at the moment there is some good news on that front.  Widening credit spreads have increased corporate bond yields and they are now higher than they were in March 2019.  Inflation has also fallen.  Both of these factors will reduce the value places on liabilities.

At time of writing therefore charities may see an improvement in their position in comparison to last year.  The position is highly volatile however and Is changing significantly every day.

If you are concerned about the figure likely to be placed on your balance sheet there are steps you can take to help manage this.

What is not universally known is that it is the Directors /Charity Trustees who have responsibility for setting the FRS disclosure assumptions and not the Fund actuary.  You can therefore chose to use a different set of assumptions if those are more suitable for you and bearing in mind that one set of global assumptions issued by the Fund actuary can’t be specific to each employer, this is probably something worth considering, especially if your balance sheet position is important.

You may well be surprised by just how much of a difference small changes in the assumptions can make to your liabilities and therefore your deficit and balance sheet position.

I would therefore encourage employers already disclosing an LGPS pension liability to consider the assumptions used and whether or not they are appropriate.

The table below shows the potential impact of varying the assumptions used to calculate the FRS 102 liability.  Please note this will vary for each scheme and the figures below are provided as an example only (based on a scheme with a duration of approximately 20 years).

Change in assumption Change in liability
+0.1% p.a. discount rate -2%
-0.1% p.a. inflation -2%
-0.5% p.a. salary increases -1%


Indicative results showing the impact on deficit and balance sheet position based on the above changes to the assumptions are shown below.

‘Standard’ assumptions £000 Organisation specific assumptions £000
Assets 2,000 2,000
Liabilities 3,000 2,850
Deficit 1,000 850


So, for this illustrative example, a change of around 5% in the liabilities as in this case could reduce the deficit by around 18% and improve the balance sheet position by £150,000.

Therefore, you can see that for organisations participating in LGPS, it is well worth considering the use of bespoke assumptions, particularly if you are looking to manage your balance sheet. If you would like an indication of how changes could have impacted your 2019 disclosures, please let me know and we would be happy to provide these.

If you are looking to incorporate non standard assumptions, you need to consider this now as Funds usually require some advance notice that a different process will be used. We provide this service for many of our clients so don’t hesitate to contact us if you need more information.

Angela Burns

Markets have been extremely volatile in recent weeks primarily due to Covid-19.  Many countries are in lock down and a sharp eurozone recession could be on the horizon.

Many employers will be approaching their year-end with accounting figures to be produced at 31 March 2020 and will be worried about what recent market movements can mean for accounting figures.  Markets are fluctuating daily, but current conditions could actually see an improvement in the accounting position for many schemes.

The table below sets out how various economic indicators have changed since 31 March 2019

  31 March 2019 18 March 2020
iBoxx >15 Corporate Bond Index 2.35% p.a. 3.00% p.a.
Bank of England 20-year Implied inflation3.65% p.a. 3.00% p.a.*
Bank of England 20-year nominal spot yield1.60% p.a. 1.30% p.a.*
FTSE All Share Total Return Index 7235.16 5213.67

*estimate based on gilt yield movements

Gilts yields have fallen since 31 March 2019 from 1.60% p.a. to around 1.30% p.a. (although the figure was as low as 0.5% p.a. only a week or so ago).

However, credit spreads have increased dramatically, and the result is that corporate bond yields (on which accounting valuations are based) have increased by around 0.65% p.a. (and have effectively doubled over the last week or so)

Inflation has decreased by 0.65% p.a. and has been much more stable than the gilt or corporate bond yields.

Overall, for schemes with inflation linked benefits, accounting liabilities as at 31 March 2020 (if market conditions are unchanged from now) will have reduced, all other things being equal.

The overall funding position will also depend on how assets have performed.  Schemes with high equity exposure will have seen a significant drop in asset values with the FTSE All Share Total Return Index falling by almost 30%. 

Schemes with Liability Driven Investment (LDI) are likely to see an increase in asset values due to the significant falls in gilt yields (albeit these returns are very volatile).  Well hedged schemes (against gilt yield movements) may therefore see a material improvement in their position.

The table below sets out our broad estimated position for a sample scheme assuming different investment strategies.

31 March 2019 Accounting Position

Assets:                 £30m

Liabilities:            £35m (50% linked to inflation movements)

Deficit:                 £5m      

Investment strategy 1:   30% LDI, 20% Corporate Bonds, 25% equity, 25% diversified growth

Investment strategy 2:   75% equity, 15% corporate bonds, 15% gilts

Estimated position at 16 March 2020

  31 March 2019 Actual 31 March 2020 Estimated Investment Strategy 1 31 March 2020 Estimated Investment Strategy 2
Assets £30m £27m £24m
Liabilities £35m £29m £29m
Deficit (£5m) (£2m) (£5m)

As you can see from the table, we expect that schemes with a high proportion of hedging and a more conservative investment strategy will have an improved accounting position based on current market conditions.  Schemes with a high-risk strategy and lower proportion of hedging may still be in a similar position to last year despite huge falls in asset values.

Please speak to your usual Spence contact if you have any queries or would like some preliminary figures in advance of your year end.

Brian Spence

Our response to Covid-19

We are continuing to evolve our response to COVID-19 as the situation develops. In order to maintain our highest levels of service for all clients, and to ensure minimum risk to the wellbeing of our staff, we have decided that from Tuesday 17 March, our staff will work remotely.

All non-essential business travel has also been cancelled.

Impact of Office Closures

In order to ensure that we can continue to operate our business normally, we have taken the following steps:

  • All mail will be redirected to our Belfast office.
  • A very small team will attend the office in Belfast (or Glasgow if Belfast became unavailable) by walking or driving to work.
  • Any relevant correspondence for onward digital processing and outgoing post will be dealt with by this team.
  • The quickest way to contact our teams will be using telephone or email.

Technology to Support Home Working

Our business has been essentially paperless since 2009.  Our IT infrastructure is entirely cloud based so we have no physical servers.  We use a combination of Microsoft online software (e.g. Office 365) and applications hosted on Microsoft Azure. Our telephony is on Microsoft Teams and is fully cloud based.

Our main pensions administration software Mantle is hosted on the Google Compute and Amazon Web Services cloud platforms.

This means that we are able to fully support all services to our clients including administration, actuarial, pensions payroll, treasury and investment management services as normal.

Wellbeing of our Members of Staff

We remain committed to helping our members of staff through this period, and ensuring that we minimise the risk of them catching the virus.

Using Microsoft Teams for managing remote meetings with and without video allows us to continue to interact closely together and with our clients.

We will be holding weekly all staff briefings, and maintaining regular communication within and between teams supported by Microsoft Teams.

Our Business Continuity Planning team continues to monitor the situation, meeting twice a week, and communicating with our wider team regularly.

Communication

We will continue to update you on our preparedness, the fluctuations in investment markets and the general position on your pension scheme as the situation develops. 

Please do continue to contact us as normal if you have any questions at all.

Alan Collins

In the current challenging times on so many fronts, thinking about/writing about actuarial valuations leads me to ask “so what” from time to time and you may well feel the same.

However, if not, then hopefully the following will give some useful reminders / pointers for sponsors and trustees with an actuarial valuation due in the coming weeks and months.

  • Unless schemes are already very well-funded and very well protected against interest rate movements and have low levels of growth/equity assets, their funding level will have taken a hit over recent weeks. The degree of the hit will be dictated by the levels of exposure in these areas. My experience is seeing schemes which are broadly unaffected (perhaps still 1%-2% down) to seeing with funding levels falling by 15% or more since around mid-February.
  • For open schemes, even those that are well funded, current market conditions will result in higher expected costs of benefit accrual. This is primarily due to lower interest rates / lower long-term rates of expected investment return. For a typical final salary or Career Average Revalued Earnings (CARE) scheme, it could increase costs by 5% of salary or more. Unless other action is taken, this increased cost will fall on company sponsors.
  • Given the above, I think it is very important to know where you stand – technology is available now such that all trustees and sponsors should be able to ascertain their funding positions on an up-to-date basis. Peter Drucker’s famous saying of “what gets measured, gets managed” has never been truer than today.
  • As legislation stands, actuarial valuation dates must be no more than 3 years apart. So, you will not be able to defer the effective date of your valuation. I assume it is pretty unlikely that schemes will want to bring valuation dates forward to now unless there is a requirement/very good reason to do so.
  • So, your results need to be measured at the valuation date. However, crucially, any resulting funding recovery plan does not. A recovery plan (and schedule of contributions) can take account of changing (and hopefully improving) market conditions during the 15-month period in which valuations need to be completed. I have seen this occur several times now e.g. valuations which took place shortly after the credit crunch in late 2007/early 2008 and those which took place shortly after the EU Referendum vote in 2016, showed much better positions by the time they were due to be signed off.
  • Reducing risk may mean selling some assets at a price below the peak they reached just a few weeks/months ago. However, if doing so can move you towards your ultimate goal more effectively, then it will be the best thing to do. Over the early 2000s, I saw many trustees miss out on de-risking opportunities while they hung on for market to “return” to pre-crash levels.

Overall, managing a defined benefit pension scheme remains a long-term enterprise. I hope this bump in the road, like several others before, is overcome quickly. My key messages are keep thinking and planning for the long-term, keep up to date with what is happening (with the scheme and your sponsor) and continue to look to reduce risk gradually over time when you can. 

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