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Scheme Members will have received
recently (April 2011) a letter from the Pensions Trust reconciling the
2006 Actuarial Valuation (produced in 2007 as a snapshot of our fund's
position on December 31st 2006) with the 2009 Actuarial Valuation (a
snapshot of December 31st 2009 produced in March 2011).
There has not been a letter like
this for previous Valuations. Insofar as the letter represents a
broader attempt to communicate with Members it is a welcome trend.
On the other hand, the presentation in the letter disguises some
questionable Trustee decisions.
Readers who are not familiar with
the purposes and content of a valuation, or not familiar with longevity
statistics, might benefit from reading AMIPP's commentary on the
2006 Valuation.
(There are also comments on the
2003 and
2000 valuations).
The valuation for the I-Plan is separate and not discussed here.
The letter notes that this
valuation was completed right up against a regulatory deadline. It
is often the case with schedules that finishing late is a consequence of
starting late. The policy communicated to members about interim
valuations has been that
there would be an early valuation if
"there is a significant fall in the value of the assets, or other
change in market conditions which could have a significant adverse
impact upon the financial position of the Plan". In
mid 2009 the banking crisis was a known factor and IBM had announced its
forced retirement and scheme closure plans. The Trustee could have
started a valuation of December 31st 2008. The regulatory deadline
would then have been March 2010. The Trustee decided the
significance of the situation did not justify a 2008 valuation.
One year of the delay in telling members the
effect of the events (and getting a recovery plan started) has been by
Trustee choice.
The letter
acknowledges that the assumptions used for 2006 proved unduly optimistic
in practice. The multi-year assumption for investment returns was
7.3% p.a, a real rate of return of 4.4% given the inflation assumption
then of 2.9%. A guess that proves wrong is not necessarily a bad
guess, but the high level of this assumption adds weight to
the suggestion that the infamous Guarantee allowed
IBM to impose "best estimate" assumptions as opposed to the
"prudent" assumptions used by most trusts. (The text of the
Guarantee has been kept secret from members). The terms of the
Guarantee were a Trustee choice.
The new
policy, to invest more conservatively, will lessen the concern of
members about the zigzags of the financial markets. It should be a
security gain for members, although you might expect that to be offset
by an even more aggressive approach by IBM to reducing its pensions
costs.
Those of you
who read the actual Valuation should be wary of the elusive distribution
of information. The "Return on investments" is specified as "See
below" but the table below is of discount rates. Many pages away
it is said that the investment return is equal to the discount rate plus
0.5% pa. No explanation of the 0.5% is provided. Previous
Actuarial Valuations have not made a significant distinction between
return on investment and discount rate - "The discount rate is the
expected return, net of investment management expenses,...".
The letter
refers to "discretionary pension increases beyond those guaranteed
out to 2020". This is strange wording since until 2020 there
are no discretionary increases - the benefit increases are specified by
the deeds. However, the letter formalises the intent of no
increases after 2020. The prospect of increases was always a
mirage, to gloss the Guarantee. In
Newsletter 38
(before the 2009 degrading of actives' benefits) AMIPP noted "Logic
says that zero increases on pre-1997 service, after 2020, is the trust
board's best estimate. "
In respect of
CPI the letter says "The Trustee asked IBM if it was willing to keep
RPI as the index measure but IBM declined and the Trustee was obliged to
move to the CPI basis". This is different from the explanation
pension services has given individuals before. Before, they have
said that IBM was asked if it wanted a change to the deeds. This
new account seems to acknowledge that no change to the deeds was
required to retain RPI. What is still missing is the reasoning why
the Trustee felt it was obliged to move to the CPI basis. There
are those who think the obligation was the opposite - that the words of
the deeds, in conjunction with 25 years of practice and statements,
created an obligation to continue with RPI. The regulations do not
force a change from RPI. The Trustee has
chosen to go along with the movement of £175m from your future benefits
to the IBM shareholders.
While on the
subject of CPI, there are a couple of predictions in the valuation that
may raise eyebrows. The anticipated difference between RPI and CPI
is 0.75% p.a. (3.0 - 2.25) This is on the high side of
predictions in the press and if it eventuates the damage will be higher
than AMIPP calculated in
Newsletter 46.
(Which used a 0.5% difference). The Valuation also predicts that
the fluctuations of RPI will result in an average of 2.2% for RPI capped
at 2.5%. It will require RPI to be below 2.5% for some years in
order to achieve this average. (RPI is currently 5.3%).
The letter
says that "IBM in the UK, with the support of the IBM Corporation, is
expected to be able to meet its pensions obligations". This is
hardly a surprise in the light of the Corporation's record profits.
Is the paragraph meant to suggest that the Trustee was once advised that
IBM in the UK, with the support of the IBM Corporation, was expected to
be unable to meet its pensions obligations? If so, why were
members not told? If not, what did the Trustee gain from the
Guarantee to outweigh the independence that it lost?
A recovery
plan that extends for ten years is common, although only the first years
are meaningful because recovery plans get reset whenever there is a new
Actuarial Valuation.
Overall, the
tone of the Valuation is to take more seriously the prospect of cutting
the C-Plan free from IBM, either by building up sufficient funds to run
it that way or by buying our pensions from a pensions provider (who
would be regulated by the Financial Services Authority and have large
reserves). The official absence of the potential discretionary
increases means that the Trustee is no longer in the position of the
donkey following the dangled carrot which is attached to its harness,
and can more easily adopt policies expensive for IBM.
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