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In whose backyard?
Advocates for improved efficiency in defined benefit (DB) plan-related
risk management would argue that an asset mix policy based on an
asset-liability mismatch with a near-static overweighting of equities
is no longer a viable long-term risk reward proposition. This is
quite true given prevailing capital markets and other challenges
facing the pension industry today. Instead, a more dynamic form
of plan asset-liability mismatch risk management seems needed and
ought to be implemented on the basis of active risk budgets for
allocating among risks, rather than asset types.
Yet, asset-liability studies continue to focus on onetime adjustments
in the policy asset mix over some planning horizon, while leaving
other potential decision variables either intact or observed for
residual impact. Further, asset-liability studies and resulting
riskmanagement initiatives typically try to respond to a composite
of various reported (non-economic) plan liability and pension expense
measures. This produces unclear policy asset-mix recommendations.
Allegedly, traditional recommendations have featured a near-static
passive policy exposure which typically consists of an overweighted
and under-diversified equities holding combined with a rump holding
of longduration conventional fixed income instruments. Also, the
recommended policy asset mix in many instances may not reflect any
meaningful inclusion of inflationlinked bonds, despite the presence
of inflation-indexing embedded in the benefits formulae of some
plans.
Some have argued that fuller on-balance sheet disclosure and eventual
market-sensitive pension accounting may ensure that investment management
occurs more efficiently in a liability-relative sense. However,
market-sensitive pension accounting will reflect only a narrow and
one-sizefits-all interpretation of economic liability from a planrelated
governance standpoint. The consequent period-byperiod, marked-to-market-related
expense and surplus volatility may simply result in existing inefficiencies
being traded for a host of new ones, related to both broad corporate
and within-plan risk management requirements.
One corporate inefficiency involves potential for distortions
in corporate risk reduction behaviour because plan-related assets
and liabilities would be marked-tomarket while other corporate assets
and liabilities would not. Genuine corporate risk management efficiency
demands that all risky corporate exposures be consistently marked-to-market
to generate the relevant variance-covariance matrix. Indeed, even
in terms of potential mark-tomarket problems within the plan alone,
there remain significant unresolved, fair-value measurement-related
issues. As a consequence, a potential inefficiency may involve possibly
dangerous overweighting in illiquid asset types, or other asset
types with infrequent price discovery.
Value Estimation
A comprehensive plan-related marking-to-market involves more than
discounting an actuarially determined future benefits stream. The
fullest economic representation of the pension promise must reflect
disclosure of, and ongoing value estimation for, a host of embedded
credit-risky options held by various plan-related stakeholders.
We are not arguing in favour of one form of corporate pension
accounting standard (smoothed versus fully volatile, period-by-period
marked-to-market pension surplus and expense), but only suggest
that the sands are constantly shifting. One corollary of value relevance
studies is that such change in pension accounting standards ought
not to matter for pertinent, economic-based decisionmaking, given
the evidence of prevailing underlying capital markets’ semi-strong
efficiency. Pension accounting reform, along with some aspects of
pension funding, tax, and other plan-related reforms, represent
examples of potential environmental disturbances for DB plan sponsors.
Such disturbances do not themselves represent a source of first-order
impact on the prevailing economic risk-reward proposition posed
by DB pension plans for their stakeholders’ economic welfare.
However, they may nonetheless provoke behavioural responses by one
plan-related stakeholder, in this case, the corporate sponsor. Inasmuch
as the underlying economic riskreward proposition remains essentially
the same before and after pension accounting reform, these behavioural
adjustments by corporate plan sponsors might, as a consequence,
become damaging for plan members.
In responding to the environmental disturbances noted above, insider
trustees could be put under greater strain in terms of arbitrating
on potential governance-related conflicts arising as insider trustees
attempt, over time, to balance the needs of the corporate sponsor
while observing their fiduciary duty to plan members. A corporate
sponsor can agitate unilaterally for imposition of a revised corporate-friendly
(immunized) policy asset mix within the plan (or even outright plan
termination and windup) to suit its own changed risk-management
preferences and risk-tolerances in reaction to changed pension accounting
standards.
However, a more worthwhile alternative recognizes that good plan-related
governance is only assured if unintended welfare-damaging consequences
arising from environmental disturbances (i.e., changes in corporate
pension accounting standards) are either mitigated or at least appropriately
rest with the relevant affected plan-related stakeholder and not
inadvertently with plan members.
Good Governance
A necessary pre-condition for the conduct of good plan-related governance
is access to as many means for implementing high-level risk management
initiatives as there are number of distinct plan-related stakeholders
that might be impacted by specific plan-related environmental disturbances.
This allows a clear separation of risk management initiatives between
those that are appropriate at the plan level and those that specifically
respond to plan sponsor requirements at the corporate level, hence
targeting the specific needs and preferences of the affected plan-related
stakeholder.
Fortunately, with increasingly cost-effective, commoditized access
to derivatives markets, such separation is now viable, and risk
management solutions can be specifically tailored to the unique
needs and tolerances of most plan sponsors. Investment management
ought to be encouraged to pursue prudent longer-term, value-adding
initiatives within the plan itself while any short-term-oriented
corporate risk management requirements are addressed with a swap-based
overlay at the corporate level. This can address potential corporate
concerns regarding excess short-term volatility of corporate pension
expense and plan surplus on its financial statements, while respecting
the fundamental longer-term economic going-concern risk-reward proposition
that the plan represents for plan members.
While changes in corporate pension accounting standards and other
potential disturbances in the environment may provoke distraction,
governing fiduciaries need more than ever to remain focused on high-level
risk management requirements uniquely appropriate for their plan
situation. A vital initial step toward achieving efficiency in liability-relative
risk management involves a more basic plan-related governance consideration,
namely, defining in whose backyard a particular high-level risk
management initiative ought to be taken (plan sponsor or plan members)
in response to any environmental disturbances, and, once such determination
has been made, implementing the relevant risk management initiative
at either the corporate level or at the plan level, as the case
may be.
It is only by properly determining in whose backyard an initiative
is to be taken that neutrality-of-impact can be assured for all
stakeholders from a plan-related governance standpoint, thereby
ensuring that there are, and will be, no unintended negative welfare
consequences for any planrelated stakeholder as a result of misplaced
initiatives.
Endnote
Bader, Lawrence N., and Jeremy Gold, “Reinventing
Pension Actuarial Science” in The Pension Forum, vol. 15(1)
(Schaumberg, Illinois: Pension Section of the Society of Actuaries,
2003)
—Anthony Treier, portfolio manager, Fixed Income, TELUS
Corporation Pension Plan.
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