Revisiting the DB Pension Plan Model Failure

While in Mont-Tremblant covering the CAIP Quebec & Atlantic conference, I had a fat finger incident and inadvertently deleted a very important post on corporate DB plans which I was able to recover and bolster with some additional comments from senior pension fund managers and expert actuaries (see update at the end).

I recently critically reviewed an op-ed in the Globe and Mail written by Brent Simmons, Senior Managing Director & Head, Defined Benefit Solutions at Sun Life on why the DB pension plan business model has failed.

Following that comment, I received some feedback from senior pension fund managers and Malcolm Hamilton, a retired actuary and one of the best actuaries in the country.

Before I get to this, I was also contacted by Arif Sayeed who was told by Colin Carlton to reach out to me. Colin is a senior consultant at CPPIB and one of the smartest people I've met in the investment industry (a real thinker which is refreshing and unfortunately, very rare).

Anyway, Arif shared this comment on why the corporate DB plan has failed:

The defined benefit (DB) pension model was created more than a century ago. During much of its early years the management and administration of these plans was in the hands of the insurance industry. Pension contributions by a company and its employees were used to purchase insurance policies – essentially deferred group annuity contracts. When an employee retired the insurance company would pay their pension out of the general assets of the company.

It was not until the mid-1960s that trust companies together with the money management industry came up with the idea of a pension plan sponsor establishing a trust, i.e. a “pension fund”, separate from the assets of the company. Pension contributions would go into the trust and be invested substantially in equities, as well as in bonds. Investment managers argued that by investing in equities, the pension fund would be able to earn a higher rate of return, which would then result in lower contributions and lead to increased earnings for the corporation. The idea caught on like wildfire. Today the assets of almost every DB plan – other than those which have been closed to new entrants – are invested substantially in equities.

In the early 1970s, economists took a look at the way pension funds were being invested, and they quickly came to the conclusion that it did not make a lot of sense from an economic or corporate finance perspective. It is reasonable, of course, to expect that equities, being riskier and more volatile than bonds, will on average over the long run provide a higher return than bonds, and that this should result in lower required pension contributions. But in the short to medium term a substantial investment of the pension fund in equities can also lead to substantial fluctuation in the funded status of the pension plan, requiring large, unanticipated increases in contributions and creating significant risk to the corporate cash flow and bottom line. The economists argued that not only would this not enhance shareholder value – because knowledgeable analysts and investors would simply apply a higher discount rate to the expected stream of higher but more volatile future earnings of the company – but rather it would actually decrease shareholder value. Why? Because the company would be taking on all of the risk of pension deficits, and be forced to make additional contributions, most likely in bad economic/market times, yet would enjoy only limited access to the rewards of pension surpluses in good times, by taking contribution holidays to the extent permitted. The company would not be able to withdraw surplus assets out of the fund to use for its own purposes.

What many companies, of course, have chosen to do is to fritter away those temporary “snapshot” picture of surpluses in good times to further enhance the benefits to plan members, leaving a subsequent generation of company management and shareholders to deal with the consequences of a richer and less affordable DB plan.

In other words, even if the strategy is successful – and I cannot stress this strongly enough – even if it results in lower pension contributions and higher corporate earnings in the long run, investing the assets of the pension fund in equities destroys shareholder value. In fact, if the company wanted to take the risk of investing in the equity market, it would be better off doing so by using its own corporate assets – taking out a bank loan or doing a bond issue, and investing the proceeds in equities. And if no company could or would see any justification for doing that, it should not see any justification for investing the assets of the pension fund in equities.

As far as economists are concerned, this is an issue that was settled a long time ago. All economists, across the ideological spectrum from liberal to conservative, agree that the assets of a DB fund should be invested in some combination of nominal and real return bonds in a way that maximizes, as far as possible, the matching of pension assets and liabilities and minimizes any fluctuation in the funded status of the plan.

The DB pension model has failed not because the model itself is inherently defective – in fact, it is a far better and cheaper way of providing employee pensions than the DC model – but because of the way in which the assets funding those DB obligations have been invested. Why is it that earlier in this century, DB pension plans went through two episodes of once-in-a-lifetime “perfect storms” within a decade, in which their funded status declined 30%-40% each time, whereas the insurance industry, with very similar long-term obligations in their annuity business, sailed through unscathed? Surely there is a lesson here for the pension industry.

I thank Arif (and Colin) for sharing this perspective and I agree, insurance companies are much better at matching assets with liabilities but not because they invest largely in nominal and real return bonds, but because they invest across a broad basket of public and private investments, including other alternatives like hedge funds and private debt.

Let's face it, insurance companies are all about matching assets and liabilities, if they can't get it right, their whole existence is jeopardized.

Arif is right to point out many corporations squandered away their pension surpluses in good years (not surprising!) and many of them totally mismanaged their DB pensions much to the detriment of their shareholders and employees.

He's also right to point out that from and economics/ finance perspective, they would have been better off issuing debt and buying back their own shares than investing large sums in equity markets.

But as I pointed out last week in my comment, there are exceptions to the rule -- CN Pension, Air Canada Pension, Kruger's pension were examples I cited -- companies that only maintained their defined benefit (DB) plan, they bolstered them. So what can we learn from their success?

However, I am a realist and realize the economic reality confronting most large corporations simply means they cannot afford a DB plan so they typically opt to shut down old DB plans and replace them with cheaper and much worse defined contribution (DC) plans.

This is why I believe large corporations shouldn't be in the DB plan business (apart from some exceptions I cited previously). They don't get it and are incapable of fulfilling the pension promise. Businesses should focus on their core business and let pensions to the experts.

Moreover, I fundamentally believe we can offer Canada's corporations real, long-term solutions to their workers' pension needs not by de-risking them and doing away with them, but by bolstering them and creating a national plan that covers all workers properly just like CPPIB covers all Canadians properly.

As I stated last week: "If we want to improve corporate DB plans, all we need to do is look at the success of Canada's large public DB plans and model something based on their governance and investment approach."

Now, following last week's comment on the failure of the DB pension plan business model, Wayne Kozun, a former SVP at OTPP who is now CIO of Forthlane Partners, shared this with me:

Sun Life also has a bias to push companies to DC plans as I am pretty sure that they offer services to DC pensions, including asset management, administration, etc.

The author mentions that $158B in contributions were made. But he doesn't mention the nature of these contributions. They could have been because returns were below expectations but they also likely included contributions required to fund future service earned beyond 1999 and also changes to mortality tables as people are living longer than actuaries assumed 20 years ago. That does not indicate a problem with DB pensions, it just means that this risk was socialized to all members in the plan rather than each member having to bear this risk on her/his own.

Unless we see that $158B broken down then I don't think we can actually say that this proves the failure of DB corporate pensions.

But I do agree with him that the premise of a DB plan is somewhat flawed as you can think of it as a swap where the short leg is pension payments (which is essentially a long bond) and the long leg is the asset portfolio which has primarily been equities plus bonds and the bonds in the asset portfolio defease part of the pension liability. To make a long story short, the company is essentially issuing debt to invest in the stock market. As a shareholder of that company is that something that you should encourage? Probably not, but I think that DB pension are good for society as a whole as we need to make them work.

Then retired actuary Malcolm Hamilton shared this with me:

Here are some points for your consideration.

• The failure of corporate DB plans is best measured by the disappearance of DB plans in the private sector. Why do private sector DB plans disappear? Because, properly priced, employees don't want them and, improperly priced, shareholders don't want them. There is no value proposition for either employees or shareholders with interest rates this low (average 30 year RRB rate during the last 10 years = 0.7%). This isn't a Canadian phenomenon. It's a private sector phenomenon, at least in the developed world.
• I agree with Wayne's observation that traditional DB plans are, from a financial perspective, like employers issuing debt to their employees and investing in the stock market (or, more generally, in risk assets). To understand the consequences you must first specify the interest rate at which the debt is issued.
• In the private sector the debt is issued at AA corporate bond rates - say 3%. The pensions are quite expensive. Shareholders are not unhappy to see the corporation borrowing money from employees at 3%. However employees don't want to see their retirement savings earning a 3% rate of of return. Employees want higher returns at low risk. Shareholders don't want to borrow at above-market interest rates. The obvious compromise - replace the DB plan with a DC plan where employees decide how much risk they are prepared to take in pursuit of higher returns, and live with the consequences. This is as it should be.
• Contrast this with public sector DB plans - your gold standard. In the public sector the debt is issued at a 6% rate, the rate of return that the pension fund expects to earn on a portfolio heavily invested in risk assets. This is a great deal for employees... in a world where safe investments earn a 3% return they are guaranteed a 6% return. It's not such a great deal for taxpayers, who question the wisdom of issuing debt to employees at 6% when the government could just as easily borrow from the public at 3%, or less. Of course, the substance of the transaction is never shared with taxpayers.
• Public Sector DB plans do a great job for members and a poor job for taxpayers whose interests are ignored by those who are supposed to represent them. There is no magic here... just bad accounting and poor governance.

P.S. - I know that the story is a little more complicated for jointly sponsored plans but it comes down to the same thing. The plans succeed because taxpayers involuntarily subsidize members but in JSPPs, the subsidies are smaller.

And Michael Wissell, Senior Vice President, Portfolio Construction and Risk at HOOPP also shared this with me:

This is an important debate. Quantifying risk I think is at the cornerstone of this conversation. The assertion that pension plans are invested in “risk” assets is routed in the concept of the near term and shorter term implications but I would humbly submit that it is the outcome of pooling across time that greatly reduces risk that is so simple and yet so misunderstood. Risk assets over 30 years will pay you a return with near certainty, even in Japan you would have done fine if well managed and risk balanced, I just don’t know which of the thirty years will be good and which will be poor therefore if I retire at the wrong time as an individual I might be in real trouble so why take that very real risk.

Secondly how much I need (how long will I live) is much easier to manage as a group than as an individual. It is the incredible and certain risk reduction (together we have much greater certainty) that pensions offer that underpins their use in our society (you would have to believe that risk assets of all sorts everywhere will no longer over decades pay a return for this not to be true and this has not been the case for all of human history). Putting these concepts together as a pooled saver you will with certainty earn a return over time and you can target your correct risk level as you know how much you actually need. The pension good or bad debate viewed through the lens of the short term is confusing, however viewed through the certainty of returns over the long term and in my view it is only the partisan that would not want to benefit by being a part of a well managed pooled saving strategy.

I thanked them all for sharing their insights but clearly stated that as I explained here, I don't agree with Malcolm Hamilton on the true cost of public DB plans to taxpayers (think he is wrong to discount to federal government bond yields) and I still stick with my proposal to create a well-governed federal public pension fund to properly manage these corporate DB plans.

Malcolm Hamilton came back to me privately after and stated this:

Just between you and I, do you have a reason for believing that pensions guaranteed by the federal government should be valued by discounting at something other than government bond interest rates, or do you just like the answer you get when you use higher rates?

FYI:

• If the federal government promises to pay someone $100 in 30 years and does not fund it, the government values the obligation by discounting at the government bond interest rate.
• If the federal government promises to pay someone $100 in 30 years and funds it with a 30 year zero-coupon bond, the government values the obligation by discounting at the government bond interest rate.
• If the federal government issues a 30 year zero-coupon bond at par, it values the obligation at the par value of the bond plus accrued interest, which equals the present value of the principal and interest payments at the government bond interest rate.
• If an employee leaves the federal government and elects to transfer the lump sum value of their pension to a personal RRSP, the lump sum is calculated by discounting the vested deferred pension at the government bond interest rate (plus about 1% according to the relevant standards/regulations).
• BUT, if the federal government promises to pay a public servant $100 in 30 years and funds it with a portfolio of risky assets that someone believes might earn a 6% return, then the government values the obligation using 6%, thereby cutting the reported value of the obligation in half even though the obligation itself - to pay $100 in 30 years - is unaffected by the government's funding and investment decisions. The obligation is, and remains, the responsibility of the federal government.

It's fine to say that you believe that federal employee pensions should be discounted at rates much higher than government bond rates, but what is the justification? Which, if any, of the five obligations described above should be valued at government bond interest rates? Which should be valued using a different interest rate... and why?

I replied:

This is a big discussion and gets into MMT theory. My thinking is simple, a federal public pension plan isn't a corporation and therefore shouldn't be required to discount at the sovereign risk-free rate or the AA corporate bond rate.

Also, this whole debate that the members get all the rewards and bear none of the risk is misconstrued as society gets rewarded too when more people retire with certainty of income.

But it's a much wider discussion, your points are valid but IMHO, misconstrued.

Malcolm responded:

Basically you are saying that corporations should be required to behave with integrity while governments invent any pension numbers they want. Discount at 3% or 6% or 9% or 12%...just pick the answer you want and let that dictate your discount rate!

It is true that society benefits when retired people have certainty of income but certainty of income is expensive. Why should society pay for the certainty of income enjoyed by federal public servants if the benefits flow primarily to federal public servants with only some small residual trickling down to the general population?

The government could guarantee all Canadians a 6% return on their retirement savings by offering to sell special non transferable bonds yielding 6% to those who wish to buy them with their RRSPs. The proceeds could then be turned over to the PSPIB, or some similar government agency, to work its magic. Then all Canadians, not just public servants, could have a risk free 6% return on their retirement savings. Why doesn't this happen? First, because it is ridiculous, but no more ridiculous than the federal government's employee pensions. Second, because the public service is quite prepared to have the public guarantee public service pensions, heroically volunteering to accept guaranteed incomes for the good of the Canadian economy. However the public service has no interest in picking up the public's investment risk or guaranteeing the public's pensions. If you don't believe me, look at the CPP. The federal government provides no guarantee and takes no risk. All the money comes from contributors and all the risk is borne by contributors or beneficiaries. That's not how pension plans covering government employees work.

I replied:

I’m saying corporations are not governments, they’re private entities that cannot emit their currency to cover expenses so it’s ridiculous to treat governments like corporations or households. It has nothing to do with integrity!

You write: “The government could guarantee all Canadians a 6% return on their retirement savings by offering to sell special non transferrable bonds yielding 6% to those who wish to buy them with their RRSPs. The proceeds could then be turned over to the PSPIB, or some similar government agency, to work its magic.”

This argues in favour of my proposal to create a federally backed pension to properly manage corporate DB pensions using the governance model and investment strategy that Canada’s large public DB plans have adopted (as well as their shared risk model).

To my knowledge, CPP isn’t contingent on investment returns of CPPIB. I’m all for enhancing the CPP even if it’s not the best idea for the poorest Canadians.

I’d like to revisit this debate next week and take it public.

I shared Malcolm's initial feedback with some pension experts I know as I don't pretend to have a monopoly of wisdom on these issues.

Bernard Dussault, Canada's former Chief Actuary, shared this with me:

I fully agree with you and Wayne Kozun. Large DB pension plan funds invested on a long term basis in a properly diversified portfolio should not hesitate using 6% as the assumed average long term yield. Low interest rates normally play a very small role in such diversified funds.

Jim Keohane, the President and CEO of the Healthcare of Ontario Pension Plan, shared this with me:

This is a very academic argument and is a bit like comparing apples and oranges.

The first three examples are unfunded future liabilities of the federal government, so discounting them at the government borrowing rate is appropriate.

The third point about how lump sum transfers are calculated it another whole debate because the methodology creates a windfall for people leaving the plan. The logic behind this which was developed by the Canadian Institute of Actuaries (of which Malcolm was a senior member at the time) is that the amount calculated is based on what it would cost that person leaving to buy an annuity which would replicate their pension payment. This is ridiculous methodology because people pay into the plan based on the going concern discount rate and then when they leave the plan the money gets withdrawn at a much lower rate which results in them taking out much more money than they put in. And the money doesn’t come out of thin air, it comes from other plan members. If all members did this virtually every plan would run out of money. The point is, this is not a comparable situation at all.

It would only be appropriate to discount the future pension obligation if it were an unfunded liability of the federal government.

The difference with a pension plan is that the future obligation is funded through regular contributions from the employees and the employer. The question you are trying to answer is “how much money do we need to set aside to meet the obligation given a reasonable set of assumptions?” If you use any discount rate other than the best estimate of future returns on the portfolio you are going to overfund or underfund the obligation which brings up a whole series of intergenerational fairness issues.

Also, when we do valuations of companies we invest in, we don’t discount future cash flows using government bond yields, we us an estimate of the entire cost of capital. This is a standard market convention. If you applied a risk free rate – the government bond yield, you would massively overvalue the company. In the same way, if you used the risk free rate to discount the liabilities you massively overstate their value.

I would also say that this whole argument misses the point which is “what is the most efficient way to accumulate savings to fund retirements?” The answer is clearly DB plans. Pooling creates significant synergies that allow well run pension plans to produce a better outcome for the same cost or the same outcome at a lower cost.

I completely agree with Jim's points, he nails it here and it's important you all read more from HOOPP on the value of a good pension.

In my opinion, we should treat pensions the exact same way we treat healthcare and education, making sure every citizen retires in dignity and security and finding the best possible structure to pool resources and minimize the cost.

Wayne Kozun also came back to me, sharing this:

For some reason Malcolm has had a "hate" on for DB pensions for a long time, which is strange since they fed him for many years.

I don't necessarily disagree with him about using government bond rates to discount pensions. It does seem silly that you can increase the discount rate used, and thereby decrease the pension liability, by changing your asset mix to a more aggressive mix.

But I don't think this is a huge issue in Canada as the pension plans tend to be rather conservative in their discount rates. This data is a couple of years old but I collected data on plans and here is what they were using for discount rates - OTPP 4.8%, HOOPP 5.5%, OMERS 6%, OP Trust 5.15%, CAAT 5.6%, OPB 5.95%, U of T 5.75%

The real issue is in the US. Remember how in Dec 2016 CalPERS voted to lower their discount rate from 7.5% to 7% over three years. 7% is still WAY too high, but this caused a huge outcry from California city governments, etc, as it increased their pension contributions. Using this discount rate CalPERS is about 70% funded - which is a very deep hole. Change their discount rate to something more realistic, say 5%, and the funded status would likely be 50%. (If you assume that assets are 70 and liabilities are 100 and if the discount rate drops by 2% with a liability duration of 20 then liabilities go up to 140 - hence 50% funded.) There is no way that you get from 50% funded to fully funded unless you have 10%+ returns for a decade or more, lots of inflation (and no indexing on liabilities) or you break the pension promise.

I replied:

Thanks Wayne, I agree, the real issue is the US where chronically underfunded plans are one crisis away from insolvency. I do take issue with Malcolm’s insistence on using the government bond yield to discount liabilities, I think it’s silly to treat federally or provincially backed pensions and treat them like private corporations. Anyway, as you state, Canadian plans use very conservative discount rates.

Wayne replied:

But then how do you come up with a discount rate? Even for a provincial government plan? Should you use the Ontario Provincial bond rate as your discount rate for OTPP, HOOPP, OMERS, OPB, etc? If so then maybe the province should try to sewer its credit rating as increasing the spread over Canadas would really help the funded status of provincial plans. Leo de Bever and I used to joke that we should move OTPP to Newfoundland and we would move the plan to a huge surplus as the discount rate would increase!

Speaking of Leo de Bever, he also chimed in this debate, sharing this:

If the shortfall risk is shared I would agree. The other practical issue is how long one has from a regulation respective to accumulate surpluses and and work out deficiencies.

Having flexibility to suspend indexation helps to smooth out the bumps. Given all of that, I would think that something like 4% makes more sense.

In discussing these things we make the assumption that the investment and economic environment and their associated risks will stay the same.

I am concerned that a more oligopolistic economic environment and the resulting concentration of profit and wealth will eventually result in a backlash that goes beyond fixing the real issues, which could reduce return on listed equity for a while, never mind a cyclical reset.

I would agree with Leo, conditional inflation protection is a must and 4% makes more sense given the economic environment. I also agree with his observation on a more oligopolistic economic environment will result in a serious backlash which we are not prepared for.

You all need to read Jonathan Tepper's book (written with Denise Hearn), The Myth of Capitalism: Monopolies and the Death of Competition, to gain a full appreciation of how oligopolies are destroying competition and exacerbating income inequality (of course, my friends on the Left are less enamored by this book but I still implore you to read it).

By the way, for those of you wondering, Leo de Bever is doing well and shared this with me:

Have been busier than in any of my 8 formal job incarnations. In my 9th incarnation I am working to help along (as an advisor/investor/ board member) a number of innovative ideas that I see as desirable and profitable:

1. Nauticol, a methanol/fertilizer company with low emissions, water use and capital intensity.
2. Sulvaris, which makes slow-release fertilizer, and could lead the way to much more efficient sewage treatment.
3. Northern Nations, a first Nation co-operative in BC that is trying to forge JVs with non-indigenous nations to create employment and make life in the North more economically viable
4. Sustainable Development Technology Corporation, a Federal program to fund innovation
5. Vertical farming, and greenhouse agriculture production using waste heat through various channels.

Canada has a lot of people with great ideas. We have trouble quickly turning the viable ideas into products. There are lots of reasons for that, including lack of funding and resistance from the status quo.

So, life is good. I describe what I am doing as 'working with 70-year-olds to convince 30-year-olds not to behave like the typical 70-year-old.'

Canada needs to change fast, to stay internationally competitive. We are reasonably comfortable, but we cannot take that as a given. It does not help that polarized policy by soundbite is too simplistic to address real issues.

I have found 'kindred spirits', whom I have come to respect, because they believe that doing well and doing good can be profitable.

Must say that I am concerned that the Canadian pension funds are not as active in pursuing truly long-term innovative strategies as I wished they were. Lots of reasons for that too, not the least of which that benchmarks that judge long-term strategies by short-term outcomes can be dangerous to your career. Fear of failure is understandable, but as Gretsky said: I missed 100% of shots I never took. If you never failed at anything, you probably did not try much that was meaningful.

Leo de Bever is another great thinker who has a lot to say on pensions and the economy. He should really sit down and write a great book sharing all his knowledge, it would serve society well.

That reminds me, I have to get back to him on greenhouse agriculture production and put him in touch with my cousins in Crete who are running Plastika Kritis, one of the most successful private plastics company in Europe specializing in agricultural film which they also export all over the world including Canada.

Lastly, Samantha Gould of NOW:Pensions wrote a great comment on LinkedIn on what pension awareness week means for her. I left her my thoughts:

I’m glad to see young people in the UK jumping on the pension bandwagon. I’ve been harping on pension poverty for over a decade. Importantly, and the author nails it here, pension poverty disproportionately and ruthlessly strikes more women than men, so it does discriminate based on gender: “It is astounding that a woman that retires today will have a pension pot that is 1/3 the size of a man. This is mostly due to the numerous breaks in employment that a woman might ‘enjoy’ through child-rearing and caring for elderly relatives, typically later in their career. This is exacerbated by the gender pay gap which still exists across a lot of sectors.”

I'm happy to hear there are self-proclaimed pension geeks all over the world who are raising awareness on the importance of pensions. As I stated above, we need to treat pensions the same way we treat other important policy issues around healthcare, education, and even climate change.

In a well functioning democracy, we need to treat all these issues with the utmost importance.

Below, Michael Sabia, President and CEO of CDPQ, appeared on CNBC stating monetary policy will not get the world where it needs to be. Instead, investment is needed to expand the growth potential of economies, he says.

Sabia has been calling for a new paradigm on growth, one based on governments investing alongside large institutional investors to get infrastructure projects and other investments up and running.

And he's not the only one who thinks we are overly reliant on monetary policy. Pimco's John Studzinski also says economies need to rely on other vehicles such as capital investment and job creation as there's been too much reliance on monetary policy.

Studzinski, who is vice chairman at Pimco, also discussed Fed policy, the effectiveness of monetary policy, future rate cuts, negative yielding bonds, where he’s finding opportunity and the slowdown in China on “Bloomberg Markets: Asia” from the sidelines of the Milken Institute Asia Summit in Singapore.

In all honesty, even though I agree we need a new paradigm for growth, I'm not sure we have tested the limits of monetary policy and I'm bracing for QE Infinity.

Let me end by recommending another great book written by Binyamin Applebaum, The Economists' Hour: False Prophets, Free Markets, and the Fracture of Society. It provides a great history of the main ideas that economists have grappled with since Keynes and Friedman and he raises many serious policy concerns on rising inequality and what needs to be done to address it (see an earlier CNBC interview below).

Update: Malcolm Hamilton responded to the comments on this post:

You are wrong to assume that the CPP is unaffected by investment returns. If the returns are poor the 9.9% contribution rate cannot be sustained. If the Chief Actuary reaches this conclusion the federal government and the provinces must decide how to adjust contribution rates and/or benefits to address the shortfall. There is a default mechanism (higher contributions, less indexing) if they can't agree. The federal government does not guaranty the benefits nor does it acknowledge any liability for funding shortfalls. In other words, the CPP is not a DB plan. It is a target benefit plan.

"Risk assets over 30 years will pay you a return with near certainty..."

"Large DB pension plan funds invested on a long term basis in a properly diversified portfolio should not hesitate using 6% as the assumed average long term yield. Low interest rates normally play a very small role in such diversified funds."

"The question you are trying to answer is “how much money do we need to set aside to meet the obligation given a reasonable set of assumptions?” If you use any discount rate other than the best estimate of future returns on the portfolio you are going to overfund or underfund the obligation which brings up a whole series of intergenerational fairness issues."

"But I don't think this is a huge issue in Canada as the pension plans tend to be rather conservative in their discount rates. This data is a couple of years old but I collected data on plans and here is what they were using for discount rates - OTPP 4.8%, HOOPP 5.5%, OMERS 6%, OP Trust 5.6%, CAAT 5.6%, OPB 5.95%, U of T 5.75%"

These might be important points if I was advocating the use of government bond interest rates to fund public sector pension plans. I am not now, nor have I ever, advocated this. I have criticized public sector employers for the way they account for the cost of pensions. I have criticized public sector employers for the way they price pensions as an element of employee compensation. I have criticized the injustice of giving public employees 100% of the risk premium when the public, not the plan members, bears most of the risk. I have, on occasion, criticized plans for ignoring the heroic reduction in interest rates during the last 15 years in setting their return expectations, but I suggested only that they lower their expectations, not that they adopt government bond rates. The following quotation comes from the introduction to the report Philip Cross and I wrote for the Fraser Institute last year.

"Canada’s public sector DB plans have done a superb job for their members. The plans are capably and efficiently administered by boards operating at arm’s length from government. These boards faithfully represent the interests of plan members. They collect contributions, maintain records, pay pensions, and manage investments. Their practices, as described in the World Bank study, are exemplary.

Canada’s public sector DB plans deliver extraordinary pensions at an affordable price. They are well funded. Their investments perform well relative to other pension plans and relative to the benchmarks they set for themselves. They operate efficiently by exploiting economies of scale. Most importantly, they enjoy the confidence and support of their members."

Our criticism is the use of a discount rate equal to the expected return on assets to put a price on the pensions that employees earn as part of their compensation. Using this discount rate, as opposed to the yield on long term government bonds, cuts the estimated cost of the pension in half. By so doing, it distributes 100% of the expected reward for risk taking to members who bear at most half, and in some instances none, of the risk. I thank Wayne, Michael, Bernard, Jim and Leo for their comments. They are welcome to their views of how one should fund public sector pension plans and how one should estimate the future returns on a pension fund. These things have nothing to do with my criticism of public sector pension plans.

Let me repeat my criticism as it relates to the most egregious abuser, the federal government. The pension fund managed by the PSPIB is not a trust fund. The plan members have no right to the assets in, or the returns on, the pension fund. The pensions are not paid from the pension fund. Basically, it is public money set aside in a "shoe box". The directors have a statutory duty to represent the interests of plan members in setting investment policy but the benefits owed to plan members are not influenced in any way by the performance of the pension fund. The benefits are a statutory obligation of the federal government. What then is the purpose of the pension fund? It is to allow the federal government to cut the reported cost of the pension plan in half by giving the chief actuary an excuse for using a 6% (4% real) interest rate, which he or she does. The reduced "price" helps only members, who are paid more and contribute less. Consequently the reward for risk taking goes to the members while the public bears the risk. Perhaps someone could comment on this.

I don't hate public sector pension plans. I hate the way they are being used.

Finally, let me comment on Jim's attempt to compare the valuation of guaranteed pensions to the valuation of risky investments.

"Also, when we do valuations of companies we invest in, we don’t discount future cash flows using government bond yields, we us an estimate of the entire cost of capital. This is a standard market convention. If you applied a risk free rate – the government bond yield, you would massively overvalue the company. In the same way, if you used the risk free rate to discount the liabilities you massively overstate their value."

I am not advocating the use of government bond rates to value risky investments. I advocate the use of government bond rates to value safe pensions the cost of which is guaranteed by the public. If a pension is tied to fund performance, I have no objection to using the expected fund return to price the benefit because the pensioner, not the taxpayer, is bearing the risk. Jim, on the other hand, wants to price pensions using the fund rate of return no matter how much of the risk is borne by the public. He believes that HOOPP deserves to be rewarded for taking investment risk... that it is his job to make sure that HOOPP is rewarded for taking investment risk. Then he rejects any suggestion that the public should be rewarded for the risk that it bears. This, not the choice of a funding discount rate, is where we disagree.

I thank Malcolm for sharing his wise insights and clarifying his position and I think it's only fair that I let him respond to the comments on this post.

However, Canada's former Chief Actuary, Bernard Dussault took issue with Malcolm's comment, stating this:

Contrary to what Malcolm points out below, the CPP is not a target benefit plan because in case of underperforming investments, only the indexation might be reduced, not whatsoever the accrued benefits.

I thank Bernard for sharing this. Bob Baldwin of Baldwin Consulting also shared this with me:

Between 2000 and 2010 a number of public employee pension plans in Ontario made the indexation of benefits contingent on the funded status of the plans. In each case, the contingent indexation only applies to initial benefits based on service after contingent indexation was introduced. Thanks to 1997 amendments to the CPP, the indexation of base CPP benefits can be eliminated if the base benefits fail to meet their required financial test and finance ministers cannot agree to correct the financial problems through increased contributions. The elimination of indexation does not distinguish between base benefits earned before and after the 1997 amendments to the Plan. All indexation is eliminated until the financial problems are corrected

The newly created additional benefits have a different financial test. If they fail their test, accrued benefits not yet in pay and indexation will both be reduced by equal degree.

I thank Bob for sharing this comment, however, Bernard Dussault was not in agreement:

Contrary to what Bob Baldwin states above, the current CPP2 regulations may reduce only benefit indexation in case of CPP2 financial hardship, not the accrued benefits. Besides, it is intended to eventually revise these regulations for possibly the eventual reduction of CPP2 accrued benefits.

Still, Bob Baldwin came back to me:

In October 2018, the Office of the Chief Actuary (OCA) issued Actuarial Study Number 20, Technical Paper on the Additional Canada Pension Plan Regulations. The purpose of the Report was to explain the new sustainability regulations. The steps to be taken if the Plan does not pass its sustainability test are summarized on page 43 and I present them below:

The benefits in pay are adjusted by reducing indexation for six years following the end of the review period, with resumption to regular indexation thereafter, and benefit multipliers lower than 1 are applied to new benefits for all beneficiaries who start their benefit after the end of the review period.  

In February of 2019 the former Chief Actuary, Jean Claude Menard summarized the default adjustments in a presentation to the CD Howe Pension Policy Council. The contents of his slide are below. 

Main adjustment mechanisms

• Adjusting benefits of current beneficiaries 
• Modify indexation of benefits in pay for a specified period (6+ years) 
• Limits on indexation adjustment: 60% -200% of CPI • Benefits are not reduced from one year to the next
• Adjusting benefits of future beneficiaries (current contributors) • Multiplying starting amount by “benefit multiplier” (depends on the year of uptake)
• Benefit multiplier is aligned with the value of extra/forgone indexation 
• Increasing additional contribution rates – last resort in the case of deficit

The documents I cited are available on the website of the OCA.

But Bernard Dussault told me as far as he is aware, the proposals Bob Badlwin is discussing above are just that, proposals that have yet to be implemented. Bob confirmed this but noted the following:

Bernard is right that the regulations are not yet in force. The federal government has adopted them but is still awaiting the necessary degree of provincial approval.

We can note however, that when CPP benefit reductions were introduced in legislation passed in 1997, most of the reductions applied to benefit calculations starting in 1998. Accrued benefits that had not begun to be paid were not protected. To my knowledge this is the only actual example of a benefit reduction in the history of the CPP.

Malcolm Hamilton shared this with me on CPP benefits:

• On CPP benefit reductions, much has been written about what the CPP can and cannot do. Is it not clear that, with the support of the provinces, the federal government can amend the legislation to change the benefits? The benefits have been improved on many occasions. Did we not reduce the pensions of those retiring after the mid 1990s by changing from 25% of the 3-year average YMPE to 25% of the 5-year-average YMPE? Can we not increase the age at which people draw full benefits from 65 to something greater? I suspect that we can do almost anything that is sensible, even if it is not what the plan administrators imagine we will do.
• On the need for better pension plans in the private sector, what Jim seeks (see below) is essentially what Keith Ambachtsheer proposed 10 years ago - the Canada Supplementary Pension Plan (CSPP). The CSPP was set aside when the federal government decided to increase the Canada Pension Plan instead. The new, improved Canada Pension Plan is now being implemented. As is often the case in Canada, the improvements are deemed inadequate as soon as they are introduced. Then the search begins for another, even better, government program to supplement all the previous programs (OAS, GIS, the original CPP, the CPP expansion, RPPs, RRSPs, RRIFs, TFSAs, PRPPs, etc). You would think that we had a terrible problem with senior poverty in this country but I haven't seen anything suggesting that today's seniors have a materially lower standard of living than working Canadians. Yes, some seniors are poor... but many working age Canadians are poor as well.

I thank Malcolm for sharing these insights.

Interestingly, Bernard Dussault shared this on "The DB Pension Plan Model Failure":

When both the CPP and the three public pension plans covering the members of the federal public service, the Canadian Forces and the RCMP started investing their net contributions in private market (January1998 for the CPP and April 2000 for the public plans), the real rate of return assumed on the underlying funds for purposes of the triennial statutory actuarial reports was 4%.

Since then, 4% was tweaked a little bit (slight increases) a few times to come back after a while essentially to 4%.

Despite the disastrous negative return of 14% return on the CPP fund in 2008, the prescribed 9.9% contribution rate could until now be securely maintained each year since 1998. Likewise, even if the plan covering the federal public servants was subject to a significant 9.4% (of plan liabilities) deficit as at March 31, 2011, the plan had as early as March 31, 2014 developed a 3.9% (of liabilities) surplus.

In other words, following the 2008 extreme downturn, by far the worst economic downturn since 1929, two well designed and properly governed DB pension plan proved they could well survive without having to make any change to their DB design/structure. This tells me that if anything needs to be changed to the DB plans, it is their governance, particularly the financing policies, e.g. contribution holidays should be fully prohibited, severe measures should apply when the special contributions required following a deficit are not paid, valuation assumptions should be set on a realistic basis erring on the safe side, etc.

With such proper financing policy, the fluctuations in the level of contributions are normally minor and of short duration. If this would still be a major concern for a sponsoring employer, there would then be a case to offer to the plan members whether they are interested in taking over the underlying small financial risk pertaining to such fluctuations in the contribution rate.

I thank Bernard for his incredible insights on the CPP and DB pension plans. Malcolm Hamilton, however, took issue with Bernard's comments:

Bernard must have forgotten the reasons why the CPP and the the public service pension plan (PSPP) performed so well in 2008:

• The CPP had no problem because it was only 20% funded. The losses were small because the CPP had so little to lose relative to its liabilities. Even if the entire pension fund had been lost, a return of -100%, the contribution rate would have increased by less than 2 percent of covered payroll. What can we learn from this? Badly funded pension plans shine in bear markets because they have little to lose.
• The PSPP had no problem because the assets supporting benefits earned prior to 2000, 75% of the pension fund in 2008, were held in a superannuation account earning a guaranteed (by the federal government) 7% return. Only 25% of the pension fund was actually invested in the capital markets. What can we learn from this? It's nice to have the federal government guaranteeing a 7% return on 75% of your pension fund in a catastrophic bear market.

The CPP and PSPP excelled in 2008 due to poor funding and government guarantees. Good design and exemplary governance had nothing to do with it. In fact, neither is evident.

I obviously don't agree with Malcolm on that last point, there's no question that good governance had something to do with limiting the losses in 2008.

Bernard Dussault was also kind enough to share this on Malcolm’s reaction to his observations on the CPP and the federal Public Service Pension Plan (“FPSPP”), i.e. the plan described in the PSSA (Public Service Superannuation Act):

Let me first clarify that my observations exclusively pertained to:

• FPSPP2 implemented on April 1, 2000 subject to a fully funded financing policy, as opposed to FPSPP1 implemented on 1954 subject essentially to a pay-as-you-go (i.e. no or 0% funding) financing policy. FPDPP1 deals with pension accruals from 1954 to March 31, 2000 while FPSPP2 deals with post March 31, 2000 accruals. Actually, the sole difference between FPSPP1 as at March 31, 2000 and FPSPP2 as at April 1, 2000 is the financing policy, i.e. no funding vs. 100% funding, respectively. Some FPSPP2 provisions were amended/modified on a few occasions after April 1, 2000, but the financing policy was not.
• CPP1, i.e. the existing 1966-implemented CPP, which is subject to a partially funded (about 20%) financing policy since 1998, as opposed to CPP2, which was approved in 2016 to become effective in 2019 subject to a fully funded financing policy.

As Malcolm’s comments on the FPSPP pertain as a whole to both FPSPP1 and FPSPP2, while mine pertain exclusively to FPSPP2, Malclom’s conclusions are not relevant as a rebuttal of my observations. By converting FPSPP1 into FPSPP2 on April 1, 2000, the federal government was successful in correcting as well as anyone could have the inadequacies of the pay-as-you-go financing method. Once you recognize being responsible of a problem (FPSPP1 paygo financing) that you have caused by addressing it as well as could be (FPSPP2 full funding policy), you have to live with the unchangeable reality and stop repeatedly conveying that you regret having caused it, as no more can be done to address it.

If CPP1 actual demographic and economic experience had in aggregate been less favourable than its statutory assumptions from 1998 to now, the 9.9% contribution rate would have had to be increased and/or the prescribed level of pension indexation benefits would have had to be decreased. Neither happened because experience was better than the well-set assumptions (investment return being the most impacting one) and because of the quality of CPP1’s designed and explicit partial-funding financing policy. True, in case of extreme financial hardship, e.g. no investment earnings at all, the CPP1 9.9% contribution would need to be increased by no more than 2% of contributory earnings. Besides, if this was to happen, it would be a problem, even if CPP1 is only 20% funded, not only because any big or small, temporary or permanent, increase in the contribution rate is the main reason why we are having that “DB Pension Plan Model Failure” discussion but also because CPP1 would not be meeting the objectives of its 20%-partial-funding financial policy. 

The failure to meet the objective(s) of a DB pension plan’s financing policy is always a problem irrespective of the targeted funding level. If CPP1 had been implemented on a full funding basis in 1966, the contribution rate would be no more than 6% rather than the actual 9.9%. Any increase beyond 9.9% would be most unwelcome as a major financial problem for employers and workers and a major political problem for the federal and provincial governments.

I thank Bernard for sharing this with my readers.

And lastly, Jim Keohane, President and CEO of HOOPP, shared this with me after reading Malcolm's comment:

I agree with Malcolm in that it is inappropriate for federal employee pensions to be a statutory obligation of the federal government. This setup is out of touch with the current reality.

We have drifted away from the original topic of the viability of corporate DB plans. There are many reasons why corporations are no longer offering DB plans. Accounting, the nature of the workforce being more portable, and the long life nature of pension plans all contribute to this exodus from DB plans. All these factors probably make this an unstoppable trend.

There is a significant body of evidence that shows that people are much better off being part of pooled arrangement for retirement savings. What we need to think about is how to come up with a solution that works for employers and keeps employees in DB like arrangements.

I would offer that structures like HOOPP May be where the solution lies.

HOOPP doesn’t only manage the pension plan for employers, we take the obligation away from the employers as well. HOOPP pensions are an obligation of the HOOPP trust fund. They are not guaranteed by the employers or the Province. If HOOPP became underfunded it would be up to our Board to deal with the problem. In this light, under public sector accounting standards HOOPP employers use DC accounting which appropriately reflects the relationship between HOOPP and the employer.

Employees also get the benefits of scale, pooling and risk sharing that come with being part of a plan like HOOPP. Being part of a plan like HOOPP allows members to accumulate a better more secure pension at a lower cost.

We will all be better off if in the end there is a larger pool of pension assets accumulated so that people don’t end up on social welfare in their retirement which is without a doubt the most expensive way to fund people’s retirement.

Also, something that should not be lost as part of this discussion is that the closing of corporate DB plans really is about transferring the risk to the individual and the social welfare system. This is a risk that taxpayers should be worried about.

I must disagree with Jim on one point, if HOOPP fails for any reason, I do think the province of Ontario will step in even if it's a private trust fund (it's too much of a political risk not to). Fortunately, HOOPP is over-funded and extremely well-run so there's no immediate risk of this happening.

However, I completely agree with him on every other point he raises. Importantly, closing of DB plans is a transfer of risk on to the taxpayers and pooling of pension assets under a well-governed DB plan is the best low-cost solution way to ensure more people retire in dignity and  security.

Once again, I implore my readers to read HOOPP's paper on the value of a good pension. It nicely summarizes all the important points Jim is making above and provides ample evidence to support them. I will end this comment on this note.