Society of Actuaries Approves Updated Mortality Numbers

October 29, 2014 (PLANSPONSOR.com) – With the final approval of its first new mortality tables since 2000, the Society of Actuaries (SOA) has officially revised its benchmark for calculating the financial liabilities of U.S. pension plans.

Yesterday, the society issued two reports, RP-2014 Mortality Tables and MP-2014 Mortality Improvement Scale, which effectively approve the mortality rates first unveiled in a February exposure draft of the tables. The new numbers reflect increased longevity, as measured by an intense five-year study, and will be sent to all practicing U.S. actuaries, who then decide how to implement them into real-world pension plans.

“The purpose of the new reports is to provide reliable data that actuaries can use to assist plan sponsors and policymakers in assessing the financial implications of longer lives,” Dale Hall, managing director of research for the SOA, tells PLANSPONSOR. He adds that the process of implementing the new tables takes time. In fact, according to Hall, the society’s mortality tables are just part of what actuaries consider when evaluating a plan. They also look at specific mortality studies they performed on their own plans.

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“Then they’ll layer in things such as health and wellness programs at the employer that may have an impact on future mortality. It’s usually the combination of these three factors that actually go into the final table used at a real-world pension plan,” he said.

Good news of added longevity aside, some sponsors of defined benefit (DB) plans—which rely on mortality tables to assess their pension liabilities and liquidity needs—worry about the revised numbers, which may cause increased liability and lowered funded status for their plan (see “Mortality Tables Impact Depends on DB Plan Demographics”). Hall says the SOA itself predicts between 4% and 8% liability growth for a typical pension plan upon adoption of the new tables.

The mortality figures on the new tables come from a peer-reviewed study of real retirement plan mortality experiences of participants in U.S. defined benefit plans—representing 10 million life years and over 220,000 deaths. In short, both men and women show approximately two years’ additional lifespan over SOA’s earlier tables.

Men aged 65 this year, for example, are expected to live to 86.6, compared with 84.6 in 2000; women currently 65 saw longevity increase 2.4 years from age 86.4 in 2000 to age 88.8 in 2014. Such changes translate to a possible increase in private pension plan liability, the SOA acknowledges, pointing out that some plans will feel the impact more than others, based on their demographic profile and design.

While the new tables will be widely available, the SOA does not by itself hold the regulatory authority to mandate their implementation. Nor does the society see that as one of its responsibilities, Hall said, explaining that the society’s goal was, rather, to perform “a scientific objective study on mortality.”

“We put this information out so that practicing actuaries can work with plan sponsors and auditors to make informed decisions as to what the final tables should look like for evaluating the specific plans,” he said, observing that the standards of practice for selecting a mortality table for valuing a qualified retirement plan are established by federal law. “The tables give a new place for actuaries to look at current, up-to-date information to assess the effectiveness of their own processes.”

The study itself was begun in late 2009 when the SOA’s Retirement Plans Experience Committee (RPEC) began collecting data from various sources, sifting through the materials to create the draft published early this year. Following this, both the updated mortality tables and improvement scale underwent a four-month comment and review period. Resulting constructive feedback was added to the final reports.

“Over the course of the summer and early fall we brought on several independent review teams to closely review the work our committee had done, looking for any problems,” Hall said. “We walked through the independent reviews and audits, got approval from the board of directors, and through that whole process we came to the conclusion that, yes, these are the accurate tables.”

Critics such as Michael Moran, senior pension strategist at Goldman Sachs Asset Management in New York City, have complained that the study lacked breadth, yet Hall stands by the SOA’s findings. “The analysis uses more than 10 million life years of plan experience and over 220,000 deaths. So bottom line is that we certainly walked through a lot of review on a lot of data. We’re completely confident in the results of our effort,” he said.

The SOA, a professional association of U.S. actuaries, provides research that furthers actuarial science and that is used in developing pension funding requirements.

Full versions of the 2014 Mortality Tables (RP-2014) and 2014 Mortality Improvement Scale (MP-2014) are available here.

Attorney Explains TDF Annuity Rule

October 29, 2014 (PLANSPONSOR.com) – What does the new guidance about annuity investments in target-date funds (TDFs) mean for retirement plan sponsors and participants?

While at the 2014 America Society of Pension Professionals and Actuaries (ASPPA) Annual Conference, S. Derrin Watson, an attorney with SunGard, spoke with PLANSPONSOR about what exactly the guidance allows and how annuities in TDFs will work for participants. Watson notes the IRS is trying to find ways to provide for at least part of participants’ retirement savings to be invested in annuities that will provide them with lifetime income.

In a TDF series, funds start at a certain participant age—say 55—to move underlying investments from equities to fixed income. The guidance allows the funds that are making this shift to invest in an annuity as part of the underlying investments, Watson explains. The annuity can either be an annuity that starts payments to participants shortly after retirement age or at some age in the future, say 85, to protect a participant against outliving his assets. Watson says at a participant’s retirement date, the fund manager will issue the annuity or a certificate for a group annuity to the participant, and the other assets of the TDF will be retained in the fund and reallocated.

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According to Watson, insurance companies will not issue annuities without knowing the age of the annuity recipient, so the TDF series that uses annuities will have to restrict how participants invest in the series. For example, if a 30-year-old participant wanted to invest in a more conservative TDF than the one corresponding to her age, she could not invest in the 2020 fund in the series because if offers annuities. However, if the series did not include annuity investments, the 30-year-old participant could invest in the 2020 fund.

Watson says the IRS provided in its guidance that the age restriction on TDFs in a series that offers annuities will not violate antidiscrimination rules as long as younger participants will have the same investment opportunities at the same as age as older participants do.

The IRS then asked the Department of Labor (DOL) if such funds could be used as a plan’s qualified default investment alternative (QDIA), Watson notes. The DOL said yes, as long as the TDF series that offers annuities meets all other QDIA requirements. “The DOL also said the TDFs would qualify for the safe harbor from liability against a participant claim provided by the QDIA requirements as long as there is nothing inherent in the annuity chosen that would disqualify it,” he adds.

The DOL also said plan sponsors could limit their fiduciary liability for offering annuities to participants by offering them through TDFs. The plan sponsor has a fiduciary liability to prudently select the TDF manager; the TDF manager selects the underlying investments in the TDF. According to Watson, the DOL mentioned that TDF managers could use the Employee Retirement Income Security Act’s (ERISA) safe harbor rules when selecting the annuity in which to invest participants’ money.

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