Benz Offers Insights About Effective Benefit Communications
April 28, 2014 (PLANSPONSOR.com) – Benz Communications will present a series of free webinars for plan sponsors about the topic of making employee benefits communications more effective.
The webinars are intended to give plan sponsors a roadmap
for investing in their employee benefits communication, according to Jennifer
Benz, CEO of the San Francisco-based firm.
“Employers of all sizes struggle with benefits
communication,” says Benz. “Employers and their employees need effective health
and financial education now more than ever.”
In
our introductory article last week, “De-risking corporate defined benefitpension plans,” we stated that the current, relatively well-funded status of DB plans presents
an opportunity to lower the risk level. It’s important to recognize that the
risks involved cover a full spectrum that extends well beyond the problems that
result from underfunding. This article explains the six major types of risk
that plan sponsors face.
Investment risk has been making its
presence felt since 2000 and, until recently, equity returns have been lower
than both historical averages and plan sponsor expectations. Interest rates
have lingered at or near record lows. Volatility has been high at times, with
extreme “tail-risk” events coming with unusual frequency. And increasingly high
correlations between asset classes have left investors with no safe place to
hide.
During
the great recession of 2008, all asset classes declined together. Diversification,
the traditional primary tool for managing investment risk, failed to protect
investments from significant declines. As a result, plan sponsors face great
uncertainty over how much of their pension liabilities can be funded in the
future from investment returns; they face the alternative of using the
corporation’s operating cash to maintain or improve their plans’ funded status.
Interest rate risk really came to light
because of the declines in interest rates since 2008, reaching historic lows in
2012. The calculation of the value of pension liabilities is similar to bonds,
with present values increasing when interest rates decline. In addition, the
Pension Protection Act of 2006 (PPA) imposes strict funding schedules and heavy
penalties for plans that are significantly underfunded. By an unhappy
coincidence, PPA technical calculations went into effect in the same year
(2008) that the great recession led to the collapse of financial markets and
pension asset values. While remedial legislation passed by Congress relieved
some of the pressure on these cash funding requirements, GAAP (generally accepted
accounting principles) accounting rules still require pension liabilities to be
“marked to market” using current interest rates. This means plan sponsors are
still dealing with high pension liabilities on their balance sheets and an
extremely complex regulatory environment. Bottom line: Interest rate risk is
still a major source of uncertainty.
Longevity risk is becoming more of an issue for pension plans
as retirees enjoy longer life expectancies. Mortality tables that use
projection scales are required by both auditors and the PPA. Specifically, the
Internal Revenue Service (IRS) mandated the use of mortality tables with
projection scale AA as part of the PPA. The Society of Actuaries continues to update
its recommended scales on a regular basis. In the near future, we may
transition to table “MP-2014,” a unique two-dimensional table that takes into
account both age and calendar year of death. Depending on actuarial
assumptions, participant age, and gender, this could result in liabilities that
are significantly higher than under current mortality table assumptions.
Legislative and
regulatory risk
can be summarized succinctly: Pension complexity and, in turn, fees are likely
to increase. The PPA turned the pension fund world upside down with its
application in 2008 as liabilities were measured on a “mark to market” basis
and asset smoothing was limited. Coming at the end of that year, the great
recession created the need for statutory funding relief and the result was the
Moving Ahead for Progress in the 21st Century Act (MAP-21) legislation. Until
MAP-21, interest rates smoothing was only allowed for a maximum period of 24
months.
While
bringing some cash funding relief for plan sponsors, MAP-21 also increased the
insurance premiums that are paid by plan sponsors to the Pension Benefit
Guaranty Corporation (PBGC). Moreover, with the November 2013 budget accord,
even higher PBGC premiums have been etched into pension law for the next
several years. The higher premiums produce more for the federal budget even
though they are unrelated to federal spending, attracting legislators looking
for ways to fund increased spending. With PBGC officials constantly speaking
about their need for more revenue, the real dollar cost for plan sponsors with
underfunded plans will almost certainly increase in the future.
Administrative risk stems from the
possibility of litigation over plan interpretation and plan administration. One
nettlesome issue is late retirements. Here, plan sponsors are at risk over
suspensions of benefits, mandatory commencements at age 70.5, and potential
Voluntary Correction Program (VCP) issues. A second area fraught with hazards
falls under the Defense of Marriage Act’s extension of benefits for same-sex
spouses. A third danger zone focuses around lump sum offerings, where problems
can arise over potential discrimination, subsidies, anti-selection, and
liquidity issues.
Clearly,
pension plan administration is complicated, and our society is litigious.
That’s a volatile combination, which can prove costly to pension funds. As a
result, many companies have looked to outsource their pension administration to
third parties, a trend that will probably continue in the future.
Other demographic
risk
refers to any adverse unexpected experience among the participant population
(other than longevity risk, already referenced above). Since the great
recession, there has been a significant increase in disability claims and
terminations. While the overall trend is toward delayed retirement, many
participants who were laid off during the recession and couldn’t find
reemployment have opted to commence their pension benefits early. There is also
embedded anti-selection risk in plans where participants have the option to
choose from various subsidized benefit forms.
Discussing
and evaluating these six types of risk are the key first step in any de-risking
process. Next week we’ll explain some of the major strategies plan sponsors can
employ to address the fund’s assets, liabilities, and funded status.
John Ehrhardt and
Zorast Wadia, principals and consulting actuaries with Milliman in New York
NOTE: This feature
is to provide general information only, does not constitute legal
advice, and cannot be used or substituted for legal or tax advice.
Any opinions of the author(s) do not necessarily
reflect the stance of Asset International or its affiliates.