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Quick
links
Major reforms Are necessary
New
objectives
Download PDF of complete pension funding reform proposal
About the
authors

Ethan Kra, FSA, is a consultant in the New
York office and chief actuary-retirement for the US. He is chair of
the Actuarial Resource Network. Ethan has bachelor’s, master’s, and
doctoral degrees in mathematics from Yale University. He is a Fellow
of the Society of Actuaries and the Conference of Consulting
Actuaries, a Member of the American Academy of Actuaries, and an
Enrolled Actuary. He currently serves on the Academy's Board of
Directors and formerly served as vice-chair of the Academy's Pension
Practice Council and chair of the Society's pension section and FAS
106 task force.

Donald Fuerst,
FSA, is a principal and retirement consultant and has
over 30 years of experience as a benefits consultant with Mercer.
Don specializes in the design and financing of retirement programs,
both broad-based qualified plans and nonqualified supplemental
executive plans.
| | Defined benefit pension plans provide meaningful
economic security to millions of currently retired Americans. But far fewer
future retirees can look forward to the peace of mind and lifetime income
provided by these valuable plans. Since the mid 1980s the number of plans and
covered workers has steadily declined. Today, every week seems to bring news of
another employer closing a pension plan or considering termination, often owing
to the burden of unfunded liabilities.
Future American retirees face a daunting challenge.
Social Security has never been, and never will be, enough to maintain a
reasonably secure retirement, although it may keep retirees minimally out of
penury. IRAs and 401(k)s offer an enticing solution, transferring the
responsibility and investment risk to the individual. These relatively new
retirement vehicles (IRAs were created by ERISA in 1974 and 401(k)s by the
Revenue Act of 1978) offer promise but have yet to demonstrate they can produce
real security in retirement for many Americans. While they offer the advantage
of tax-favored asset accumulation, there are many obstacles to widespread
retirement security:
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Most IRAs and 401(k) plans are voluntary, and there
will always be many who choose to use their funds for pressing current needs
as opposed to the uncertain needs of the future.
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The savings rate of Americans is amazingly low: Even
as IRAs and 401(k)s have grown, the savings rate of Americans has declined
from 10% in 1980 to less than 2% in 2003.
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No amount of investment education will make
all Americans excellent investors. The very nature of our
investment markets assures us that there will be both winners and losers among
individual investors – on average, half the investors will have below-average
results.
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Managing an asset pool during a spend-down period is
a different challenge from accumulating the asset pool. Investing in your 70s
and 80s is different from accumulating assets during your 40s, 50s, and 60s.
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Managing the longevity risk is expensive.
Approximately half of all people live beyond the life expectancy, some
considerably longer. Ensuring that an asset pool lasts an entire lifetime can
cost 30-35% more than planning for the average life expectancy.
It does not have to be this way. In the 1940s, 1950s and
1960s, many employers adopted new pension plans, at least partly because they
recognized the plans would fulfill an important need for employees – a highly
efficient way to provide economic security in retirement. Assets accumulate for
all employees, not just those who choose to save. The assets are managed
professionally and are pooled to provide efficiencies in expenses, investment
management, and longevity.
The American retirement system can be reinvigorated. A
universal Social Security system, supplemented by a robust employer-based
pension system, can provide Americans with a basic level of lifetime income and
security. Healthy IRA and 401(k) components can provide additional funds to make
retirement the golden years we anticipate.
Major reforms Are necessaryThe path to this secure future starts with major reform
of the current defined benefit rules. Few employers would consider implementing
a new plan in today’s environment. Minor fixes or patches to the system are not
enough. The funding rules of the past 30 years were America’s first experiment
in mandatory funding of all pension obligations. We have learned much from this
experiment. Far too many plans have become seriously underfunded. Far too many
employers have thrown in the towel and ended coverage because of the complicated
and volatile rules. It is time to start over. The funding rules need radical
change, not just patchwork.
The current rules are far too complex, lack
transparency, lack intuitiveness, and impose penalties on companies that attempt
to fund plans well. Most important, they do not produce well-funded plans. Let’s
look at a few examples.
The funding standard for plans is arbitrary. ERISA
allows a plan sponsor to choose among six different funding methods. These
methods can produce dramatically different mandatory funding requirements, yet
it is the sponsor’s choice of method that often dictates the level of funding
required, not an independent objective measurement of plan liabilities. To
overcome this shortcoming, an amendment to ERISA imposed another definition of
plan liability – current liability – with an additional, highly volatile,
funding requirement.
Liabilities that arise for different reasons have
different funding periods, currently ranging from 5 to 30 years, creating
strange anomalies. It is not unusual for a plan with a large unfunded
liability to have net amortization credits (reductions in required funding) if
the plan experiences investment gains. This happened frequently in the 1990s.
Benefit improvements are funded over 30 years,
producing situations in which the required funding period is sometimes longer
than the expected lifetime of the benefit recipients.
Plans that have funded ratios over 100% on
conservative assumptions may be required to pay extra “risk-related premiums”
to the Pension Benefit Guaranty Corporation. Plans that are poorly funded and
expose the PBGC to substantial risk pay exactly the same premium rate.
Smoothed asset values and average interest rates
result in meaningless funding ratios. Some plans with 100% or higher funded
ratios may have assets insufficient to pay their accrued obligations. Other
plans with funded ratios of less than 100% may have more than enough assets to
pay all accrued obligations.
Plans that experience large asset losses sometimes
see funding requirements decline. Plans that experience large asset gains
sometimes see funding requirements increase.
The PBGC is sometimes required to guarantee benefits
that employers are not required to fund (contingent benefits or early
retirement subsidies).
An employer that makes an advance contribution to
the plan has that contribution credited with interest at a fixed rate
regardless of the return on the invested funds. A $1 million contribution in
1999 might accumulate to a credit for the employer of $1.26 million by the end
of 2002 even though the invested funds might have declined to approximately
$0.8 million.
Employers are prohibited from contributing to plans
in some years when they have very strong cash flow and are required to make
large contributions in other years when their business turns down.
The list of such anomalies is seemingly endless. We
could go on, but the point is clear – the current rules are broken and require
major changes. The good news is we have learned much over the past 30 years and
it is not hard today to create funding rules that will work.
New objectivesThe first step is to establish a few basic principles or
objectives:
Plan Solvency – The most important
objective is to produce a system of well-funded, financially secure retirement
programs. Plans must be able to meet their obligations without excessive
dependence on the future financial success of the sponsoring entity. The goal
should be 100% solvency, and plans should not be allowed to stray far from it.
Predictable Contributions –
Sponsors need to be able to plan and budget for substantial pension
contributions. Temporary fluctuations in plan assets or interest rates should
not cause enormous changes in required contributions. Yet secular changes in
interest rates or the value of plan assets need to be reflected and built into
contribution levels so that solvency is attained.
Objective Rules – The funding rules
should be the same for all employers, not be subject to the sponsor’s choice
of funding methods or the actuary’s choice of interest rates. Demographic
assumptions about employee turnover and retirement age may change by plan and
be selected by the actuary with appropriate consideration of expected
experience, but the basic measure of the liability and the interest rate used
to value the liability should be established for all plans in a similar
fashion.
Intuitive Results – Simply said,
the results should make sense. When assets decline, funding requirements
should increase and vice versa. Funding ratios should have real meaning based
on the economic conditions at the time they are measured. The objectives are relatively simple. The application can
be relatively simple also. You can look at it one step at a time
by downloading this
PDF of the complete proposal.
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