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Pension Schemes: dealing with the past service liability.

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STATES OF JERSEY

PENSION SCHEMES: DEALING WITH THE PAST SERVICE LIABILITY

Lodged au Greffe on 1st July 2009 by Senator B.E. Shenton

STATES GREFFE

2009   Price code: B  P.110

PROPOSITION

THE STATES are asked to decide whether they are of opinion

to request the States Employment Board and the Chief Minster, as appropriate, to renegotiate with the Committee of Management the terms of the Public Employees Contributory Retirement Scheme (PECRS) pre-1987 debt payment agreement  and  with  the  Management  Board  of  the  Jersey  Teachers' Superannuation  Fund  (JTSF)  the  past  service  liability  to  ensure  that  this liability is dealt with within a realistic time frame, and in any event in a period not exceeding 20 years, and to ensure that this change, subject to the approval of the States, takes place within a 12 month period from the date of approval of this proposition.

SENATOR B.E. SHENTON

REPORT

Being Morally Responsible

What  sort  of  parent  would  leave  substantial  liabilities  for  his  children  and  his grandchildren (and even his grandchildren's children) in order to give the impression that he is better off today than they really are?

What sort of pensioner would take from the children of tomorrow in order to have a lavish  lifestyle  today?  The  answer  is  currently  every  parent  in  Jersey  and  every pensioner that is a member of the PECRS.

The aim of this proposition is to force Ministers to do what is right – both morally and, if you consider UK legislation, legally correct.

The problem with pension funds is that they tend to be both technical and boring. When the issue is normally raised eyes glaze over and excuses are made to change the subject. I shall, however, endeavour to keep this proposition as simple as possible.

Overview

The  States  of  Jersey  operates  two  principal  pension  schemes  for  certain  of  its employees –

Public Employees' Contributory Retirement Scheme (PECRS)

Jersey Teachers' Superannuation Fund (TSF).

In addition, one further pension scheme exists, the Jersey Post Office Pension Fund (JPOPF). This scheme, which relates to Jersey Post International Limited (a wholly owned strategic investment), is closed to new members. The assets of each scheme are held in separate funds.

The Jersey Post Office Pension Fund is accounted for as a conventional defined benefit scheme in accordance with Financial Reporting Standard (FRS17).

The  Public  Employees'  Contributory  Retirement  Scheme  and  Teachers' Superannuation  Fund,  whilst  final  salary  schemes,  are  not  conventional  defined benefit schemes as the employer is not responsible for meeting any ongoing deficiency in the schemes – albeit this point is open to debate as a constructive liability remains.

Employer contributions to the schemes are charged to revenue expenditure in the year they are incurred.

In  agreeing  P.190/2005,  the  States  confirmed  responsibility  for  the  past  service liability which arose from restructuring of the PECRS arrangements with effect from 1st January 1988. This liability is recognised in the accounts.

The  Jersey  Teachers'  Superannuation  Fund  was  restructured  in  April  2007.  The restructured scheme mirrors the Public Employees' Contributory Retirement Scheme. A  provision  for  past  service  liability,  similar  to  the  PECRS  pre-87  past  service liability, has been recognised, although this has not yet been agreed with the Fund's Board of Management. Apart from the liabilities detailed above, the employer is not

responsible for meeting any ongoing deficiency in the schemes - although this is open to question as a constructive liability remains.

There is a substantial deficit on the Jersey Teachers' Superannuation Fund (TSF) – in some ways disproportionately large in comparison with PECRS. The reasons for this disproportionate problem are significant.

TSF was carved out of the mainland teachers' scheme in 1979 or soon after. Although there was funding for the basic pension entitlement, there was no funding for annual increases of pensions in payment. These annual inflation increases were paid out of the Education Committee's annual budget.

From an early point it was known that the long-term effect of not funding these annual increases was potentially explosive and that the experience of the rest of the scheme was bad – i.e. teachers were living longer than had been expected. However, for many years, nothing was done to increase funding – i.e. to increase contribution rates. This would  have  had  the  effect  of  increasing  current  costs  and  thus  of  squeezing  the Education Committee budget. Instead of taking decisive action, the political leaders of the day gazed into the headlights of the oncoming juggernaut – seemingly hoping for a miracle.

In the late 1990s, it was suggested that the TSF should be merged with PECRS. This was  always  doomed,  since  the  PECRS  Committee  of  Management  has  always demanded that any change in the structure of the scheme should be accompanied by any deficits being adjusted in cash immediately. In the case of a merger with TSF, this would have required the States to make a cash contribution equal to the TSF deficit which  was  and  is  substantial –  and  was  not  practical  politics.  When  you  have politicians telling everyone that there is no pension problem it becomes impossible for them to cover the shortfall without admitting the truth.

This proposal eventually failed and, a year or two ago, TSF was reconstructed on the PECRS lines, but independently. For all of the time that these negotiations continued, the TSF contribution rates were not revised – so that the deficit continued to grow (as people must have known it would) and the Education Committee budget remained unsqueezed.

This is yet another example of bad financial  mismanagement by the States. Bad financial mismanagement by the politicians, and bad financial mismanagement by the States Treasury.

The Accounts show the cost of this mismanagement –

Provision for JTSF Past Service Liability  £103,100,000.00

Information on the schemes is presented in the accounts reflecting the cost of the schemes to the States as the employer. In particular, information specified in FRS17 is disclosed in a note to the accounts. As both these schemes limit the liability of the States as the employer, scheme surpluses or deficits are only recorded within the States' accounts to the extent that they belong to the States, an accounting practice that is, in my opinion, questionable.

Back in 2006 I asked some questions in the Chamber concerning the PECRS Scheme. In reply to one of these, Senator Le Sueur wrote –

"It would appear from the questions tabled today, and on 6th June 2006, that because  of  the  undoubted  complexity  of  this  issue  there  may  be  some misunderstandings that are, perhaps, the source of unnecessary anxiety. It might have been simpler for the Senator to contact me or Treasury officers and to express his concerns, which could then have been dealt with. I remain happy to offer the Senator, or other interested members, the chance to meet and  to  discuss  these  complex  PECRS  issues,  in  order  to  assist  their understanding and address their queries."

However I was not asking questions because I don't understand pension schemes – I was asking them because I do.

Now Senator Le Sueur may think that I was just being mischievous or was political point-scoring. but this was not the case – although I did, at the time, take offence when former Senator Walker said on Radio Jersey that there are no pension problems' and that I should know better'.

My first concern is that the PECRS is a Defined Benefit Scheme but not a balance of cost scheme where the employer automatically makes up any deficit. As you will all know, the overwhelming majority of final salary schemes operated by employers in the UK are balance of cost schemes. Indeed the Minister for Treasury and Resources has made it clear that they will not step in to cover future deficits. This is indeed a very rare and unusual scheme.

When it comes to producing the States of Jersey Accounts the Scheme is not treated as a final salary scheme. When negotiating with the unions it is described as a very attractive final salary scheme. Technically both these statements are correct.

FRS17 provides that any deficit must be shown in the accounts if there is a "legal or constructive" liability. In the UK, this is not an issue because the 1995 Pensions Act made the Employer responsible for any deficit. All UK reporting entities therefore have to declare any deficit in their accounts. In Jersey the situation is not as clear-cut. There is no legal liability but there may be a constructive liability; it would depend upon the Court's decision as to what is generally understood by a "defined benefit scheme."

Needless to say, there is no case law and we, the States, are therefore faced with 3 choices: declare the deficit, not declare and accept a qualified audit opinion, or apply to the Court for directions. The most honest and morally acceptable choice would be to declare the deficit. I should therefore be interested to see the legal advice given to the States as to whether there is a constructive liability or not, if the question has been addressed at all.

If a Court were to deem that there was a constructive liability, then the States would have  to  declare  the  past  service  deficit  in  their  accounts  using  the  FRS17 methodology. They would also be liable for meeting any shortfall in the Scheme – which is contrary to the current understanding and accounting practice.

It has to be made clear to members that the scheme is not guaranteed'.

In reply to one of my questions the Minister for Treasury and Resources wrote –

"The Scheme is "stand alone" and not a conventional final salary scheme. The employers are not responsible for meeting any deficiency in the Scheme other than the pre-1987 debt. Accordingly, the States has no obligation to meet the cost of any deficits in PECRS, which is why it has not recognised a liability in accounts in accordance with FRS17."

Furthermore, it was stated that members were aware that the Scheme no longer had an employee guarantee, through the following statement –

"If, at a future valuation of the Scheme, the Actuary advises that its financial condition is no longer satisfactory, proposals agreed by the Committee of Management may be submitted to the States for members contributions and/or employer's  contributions  to  be  increased  and/or  member's  benefits  to  be reduced which may affect pension increases."

It is my opinion that this does not clearly reflect the changes that have been made and members  will  not  understand  the  ramifications  of  this  statement.  As  a  result  the employer retains constructive liability.

The handling of the pre-1987 debt also causes me serious concern – and this is the basis of this proposition. The whole saga of debt transfer and 82 year repayments may not have been illegal, but it certainly has the taste of Enron accounting about it. New rules in the UK make it hard for companies to get out of their pension commitments. In the UK employers must agree plans to fill pension scheme deficits within 10 years if possible – not 82 years! How can we morally leave a deficit for our children and grandchildren?

Since  the  UK  Pensions  Act  of  2004,  many  companies  have  taken  steps  to  limit additional liabilities. The vast majority of UK defined benefits schemes have been closed to new entrants.

The lack of regulation in Jersey is therefore handy as it facilitates financial creativity. But this lack of pension regulation also causes problems.

If I was asked to make two predictions for the future they would be –

The retirement age will rise and rise.

Ordinary people will have to pay higher taxes in the future to pay for the generous civil service pensions.

Indeed, a highly qualified independent pensions' expert commented on PECRS in the following terms –

"States employees should read carefully the notes to this year's accounts.

Whilst a final salary scheme (PECRS) is not a conventional defined benefit scheme as the employer is not responsible for meeting any ongoing deficiency in the scheme.'

This means that if the Scheme hasn't enough cash to pay its pensions either future  employees  will  need  to  cough  up  more  or  current  employees  and pensioners will get less."

Turning to the Scheme Accounts he commented –

"The fragile edifice that supports the minimal deficit in the pension scheme is further  weakened  by  the  import  of  other  assumptions  revealed  in  the document.  A  key  element  of  PECRS  funding  since  1988  has  been  the underlying  assumption  that  the  size  of  membership  would  be  maintained indefinitely by new members joining the Scheme in at least the same numbers as previous members retired or left it.' What this means is that the States can only decrease its workforce at the expense of the scheme's deficit as the States' funding rate has been fixed for the next 80 odd years. The pension tail wags  the  dog,  over-manning  is  justified  by  actuarial  chicanery  and  any Admitted  Body  not  willing  to  play  ball  will  be  required  to  "undertake contribution arrangements to cover difficulties incurred." This has proved no idle threat as testified by the Parish of St. Helier ."

When dealing with pensions we are dealing with people's lives. Members have to receive  certainty.  You  cannot  take  away  benefits  that  have  been  promised  and, conversely, you must not promise benefits that may not be delivered.

So we have now established that it is morally wrong to leave this liability for our grandchildren and that we need to face up to our responsibilities – not push them under the carpet. Let us now assess what this means financially –

Looking  at  the  most  recent  Accounts  (2008)  we  note  the  following  long-term liabilities –

PECRS Pre-1987 Past Service Liability  £222,288,000.00 Provision for JTSF Past Service Liability  £103,100,000.00 Total Pension Fund Liability  £325,388,000.00

In addition there is a new past service deficit liability building up.

To put this into context, the private sector taxpayer is going to have to bail out the public sector to the tune of approximately £6,500 per person for this past service deficit alone. This is substantial and the public sector should be extremely thankful to a public willing to ensure that their public sector colleagues' pensions are safe whilst they are facing redundancy, pay freezes, and reduced salaries.

And let us not forget the following –

The  picture  today  is  probably  much  worse  due  to  weak  investment performance.

In future assets may not move in line with the value of benefits.

Members could live longer than foreseen, which would mean that benefits are paid for longer than assumed.

This Proposition simply requests the States Assembly to deal with today's problems today – and not burden our liabilities on future generations. It also, at a time of increasing private sector wage freezes, redundancies, and wage reductions – highlights the true cost of the public sector final salary scheme.

The pre-1987 deficit was converted into a debt due by the States to the Scheme. That debt is backed by what is in effect a guarantee and provisions that enable the scheme to demand early payment. This debt is of some value to the Scheme since it dilutes what has on occasion been a controversially large reliance upon equities.

The current arrangement pays off the pre-1987 debt in 2084, at which point I shall be 124 years old. My youngest daughter (currently 15) shall be 91. She may well have children,  grandchildren  and  even  great-grandchildren.  No  doubt  she  will  have contributed to today's problem for the whole of her working life. What a morally responsible society we live in these days. Stick your head in the ground and let future generations pick up the pieces. Abhorrent.

Taxpayers are going the have to bail out the public sector pension deficit at a cost of millions. Members of the PECRS and JTSF fund should be extremely thankful and, perhaps, consider the generosity of the taxpayer to be equivalent of a truly substantial pay rise.

Agreement for meeting the pre-1987 debt –

15.  The framework agreed between the Policy and Resources Committee and the Committee  of  Management  for  dealing  with  the  pre-1987  debt  was documented  in  a  10-point  agreement  approved  by  Act  of  the  Policy  and Resources Committee dated 20th November 2003. The text of the agreement is reproduced below.

"1.  The  States  confirms  responsibility  for  the  Pre-1987  Debt  of

£192.1 million  as  at  31  December  2001  and  for  its  servicing  and repayment with effect from that date on the basis that neither the existence of any part of the outstanding Debt nor the agreed method of  servicing  and  repayment  shall  adversely  affect  the  benefits  or contribution  rates  of  any  person  who  has  at  any  time  become  a member of the Scheme.

  1. At the start of the servicing and repayment period, calculated to be 82 years  with  effect  from  1st  January  2002,  the  Employers' Contribution rate will be increased by 0.44% to the equivalent of 15.6%.  These  contributions  will  be  split  into  2 parts,  namely  a contribution rate of 13.6% of annual pensionable salary and an annual debt  repayment.  The  Employer's  Contribution  rate  will  revert  to 15.16% after repayment in full of the Debt.
  2. During  the  repayment  period  the  annual  Debt  repayment  will comprise a sum initially equivalent to 2% of the Employers' total pensionable payroll, re-expressed as a cash amount and increasing each year in line with the average pay increase of Scheme members.
  1. A statement of the outstanding debt as certified by the Actuary to the Scheme is to be included each year as a note in the States Accounts.
  2. In  the  event  of  any  proposed  discontinuance  of  the  Scheme, repayment  and  servicing  of  the  outstanding  Debt  shall  first  be rescheduled by the parties on the advice of the Actuary to ensure that paragraph (1) above ("Point 1") continues to be fulfilled.
  3. For each valuation the States Auditor shall confirm the ability of the States to pay off the Debt outstanding at that date.
  4. If any decision or event causes the Actuary at the time of a valuation to be unable to continue acceptance of such servicing and repayment of the Debt as an asset of the Scheme, there shall be renegotiation in order to restore such acceptability.
  5. In the event of a surplus being revealed by an Actuarial Valuation, negotiations for its disposal shall include consideration of using the employers' share to reduce or pay off the Debt.
  6. As and when the financial position of the States improves there shall be consideration of accelerating or completing repayment of the Debt.
  7. The recent capital payment by JTL of £14.3m (plus interest) reduced the £192.1m total referred to in (1) by £14.3m and if any other capital payments are similarly made by other Admitted Bodies these shall similarly be taken into account."

Financial and manpower implications

There are no financial implications for the States in respect of their overall liability in respect of these schemes – they liability remains the same regardless of the repayment periods. However, there will be an impact on cashflows as the proposition seeks to remove the liability from the States Accounts within 20 years. This will have an impact on States Budgets as repayment over a shorter period will have implications on expenditure levels.

To clarify this position let us assume that a reckless Bank Manager gave an individual an inter-generational mortgage over 82 years in order that the homeowner could buy an expensive property and still have his winter ski holiday and summer cruise. His children and grandchildren would fund his lavish lifestyle today and could, in theory, be paying substantial amounts in 60 years' time for a property that no longer exists. They would, no doubt, be very angry about the legacy left to them.

Let us assume that the reckless Bank Manager was fired (his Bank was bailed out by the Government) and the individual found God and realised the error of his ways – that it was wrong to force his liabilities on to future family members that were not yet born. He agrees, therefore, to repay the mortgage over 20 years and as a result has to alter his living standards – no more ski holidays or summer cruises, and a much more prudent approach to financial management.

It  is  impossible  to  detail  in  this  Proposition  the  exact  financial  implications,  as negotiations will determine debt repayment levels. However, the liability is being passed back to this generation – to the financial benefit of future generations. As a result, this generation will have to face up to their liabilities – with obvious financial consequences.  As  previously  stated,  the  overall  cost  remains  similar,  but  the proposition will affect cash flows.

There are no manpower implications.