Strengthening the Security of Public Sector Defined-Benefit Plans by Daniel J. Boyd and Peter J. Kiernan
from The Blinken Report, January, 2014:
"...If
public sector defined benefit plans are to be successful over the long run,
these flaws must be fixed by removing bad incentives, increasing transparency,
and imposing discipline. We recommend the following changes:
Pension Funds and Governments Should Value Liabilities and
Expenses with a Risk-Free Rate, for Financial Reporting Purposes:
"Pension funds and governments should value liabilities
and calculate costs of benefits, for financial reporting purposes, using a
discount rate reflecting the risk that the obligations will not be paid. Funds
also should disclose projected cash flows used to calculate liabilities so
that they can be discounted at alternative rates. As a practical matter, in
most cases the appropriate discount rate will be close to a risk free rate (or
set of rates from different points on the yield curve). There are some
important considerations involved in determining precisely which rate to use,
in particular whether the rate should be taxable (yes), whether it should have
a premium for liquidity (no), and whether it should be inflation-adjusted or
not. This last question is not as straightforward — pension benefits are
protected to differing degrees from inflation. A pragmatic choice that would
get most of the desired result would be to use a nominal rate. Another
pragmatic choice would be to base the discount rate on a
high-quality municipal bond rate.
"The rate generally should be risk free even
though some pension benefits are succumbing to legal attack. It should reflect
the fact that, when promised, pension benefits are expected to be and should be
honored by governments. The rate definitely should not vary with the
creditworthiness of the borrower. For example, it should not reflect the
borrowing costs of the governments in question. Otherwise, it will create the
perverse result that the governments in the worst financial trouble (quite
possibly because of pension problems) would have the lowest reported pension
liabilities, all else equal. (If the pension fund discount rate is based on
the rates at which the government can borrow, then governments in financial
trouble, thereby paying higher rates to borrow, will have lower reported
pension liabilities.)
"Even though separate
calculation of pension liabilities and benefit costs in this manner are not
required to be included in Comprehensive Annual Reports, they should
be. Standards organizations — GASB and the Actuarial Standards Board in
particular — should revisit their current standards and develop improved
guidelines for pension systems and governments. But in the interim,
governments and pension systems and governments should do this on their own
initiative.
"Discounting at risk-free
rates is likely to result in at least a $2 trillion increase in reported
liabilities for state and local governments in the United States. The estimate
of annual pension expense — what governments would have to pay if they were to
fully fund pensions without taking investment risk — is likely to increase by
more than $100 billion.
"This change would not be a funding
requirement; rather it would be disclosure of pertinent information. This is as it should be: governments,
taxpayers, and others should know the full cost of promises that have been
made, and what it could take to fund those promises without risk. Full
disclosure could be the basis of political support and a predicate for
legislative changes.
Pension
Funds Need to Disclose More Fully the Consequences of Investment Risk:
"Pension funds are
taking considerable investment risk that others bear. This risk must be
disclosed far more fully. Pension funds need to disclose the potential
consequences of investment risk not only for their funded status, but also for
the contributions that participating governments may have to make. When investment
returns fall short, they can require very large increases in contributions, and
governments make these contributions if they are to keep their side of the
bargain. But large increases in required contributions invariably come when
governments are least able to afford them, and crowd out other services and
investments of government, or required tax increases. And they erode public support
for public sector pension benefits, and for the public sector workforce.
"The Pension Committee of the Actuarial
Standards Board is headed in the right direction with its current discussion
draft of actuarial standards that explores whether actuaries should be required
to assess risk more rigorously. The Committee and, ultimately, the Actuarial
Standards Board should develop standards in this area, and those standards
should address the consequences of risk for contributions as well as for plan
assets and funded status. Other professional organizations of actuaries and
plan administrators should contribute to this effort. Until then, pension funds
and their sponsoring governments should take the lead and disclose the
potential consequences of investment risk, on their own initiative.
There Needs to
be External Downward Pressure on Investment Risk:
"No matter how professional and well-intended
pension fund boards are, and no matter how well they disclose investment risks,
current and future stakeholders in government will bear the risk that pension
funds take. These stakeholders are not at the table when pension funds
establish their risk tolerance. Because public pension funds have approximately
two-thirds of their assets in equity-like investments, have become
increasingly large, and have increasingly maturing memberships, the potential
consequences of this risk are far greater now than in the past. There must be
external pressure to moderate these risks.
"What is also needed is an effort to dampen
incentives for risk taking. Disclosure will help, but governments should
develop formal statements of the contribution risk that they are willing to
bear, and pension funds should consider these statements explicitly as they
develop their investment policy statements and asset allocation policies.
Governments Must Keep Their End of the Bargain and Pay Realistic
Actuarially-Determined Contributions:
"Any rules used to
estimate liabilities and to fund liabilities are likely to be imperfect and
controversial. But the one thing that governments should not do is ignore all
rules, and fund benefits on an ad hoc basis. The surest way to turn pension
underfunding into a crisis is underpay liabilities. This has happened in
Illinois, New Jersey, Rhode Island, Pennsylvania, and several other states, and
is happening now to CalSTRS in California... Governments should fund
actuarially-determined contributions.
"This is compounded by
rules and practices by some funds and governments that allow
inordinately long amortization periods for investment losses and actuarial
losses, and by extraordinary borrowing mechanisms that allow governments to
push the consequences of recent losses far into the future. Governments and
pension funds should sharply limit amortization periods, in general not
extending them beyond the remaining working life of current membership. The
Actuarial Standards Board should examine standards in this area very carefully,
with an eye toward shortening amortization periods.
"State governments have the legal authority to
require their local governments to make contributions, and can establish
enforcement mechanisms, such as the withholding of state aid, to ensure that
they do so. Several states have done so, as illustrated earlier in the report.
Other states should do so, too. It is much harder for states to bind their own
hands, and impose discipline on themselves. Still, a formal legal commitment
to funding required contributions backed with a potential remedy, as New Jersey
and Illinois have adopted, and dedicated revenue sources as several states have
provided for local government contributions, hold promise. If governments and
pension funds will not do this on their own, the federal government should
consider creating incentives to encourage this.
There Is a National Interest, and a Potential Federal Role, in Ensuring
Proper Disclosure and Adequate Contributions:
"Because there is a national interest in
retirement security and in much of what states and localities do, which can be
crowded out by sharp increases in retirement contributions, there is a potential
federal role in encouraging or establishing rules to help address the problems
caused by failed state and local pension systems and prevent future failures.
"The federal government
should explore options for regulatory action by the Municipal Securities
Rulemaking Board, the Securities and Exchange Commission, and Congressional
oversight to enhance reporting and transparency. Congressional action in respect
of a variant of the previously abandoned Public Employee Retirement Income
Security Act (PERISA) also could be a vehicle of federal attention. Other
legislative measures might be necessary. We do not advocate federal regulatory
attention by the U.S. Bankruptcy Courts (which could introduce confusing,
conflicting rulings and broad uncertainty), nor do we advocate additional
federal funding to the states for underfunded pensions. If
states and standards-setting bodies do not go far enough on their own, the
federal government should consider more intrusive action to monitor and police
state and local government retirement systems."
from the Nelson A. Rockefeller Institute of Government: Strengthening the Security of Public Sector Defined-Benefit Plans
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