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1 Regis House, First Floor, 45 King William Street, London EC4R 9AN Tel: +44(0) Web: 22 May 2015 Employer Debt Team Department for Work and Pensions 6-12 Caxton House Tothill Street London SW1H 9NA Dear Sir/Madam Section 75 Employer Debt in Non-Associated Multi-Employer Defined Benefit Pension Schemes Call for Evidence I am writing on behalf of the Association of Consulting Actuaries (ACA) in response to the above named consultation document issued on 12 March Our comments on most of the questions you raised are set out in the Appendix to this letter. We hope that you find them of assistance and would be happy to discuss them further if that is helpful. Please contact either me on or my colleague, Chris Fletcher on who prepared this response Yours faithfully David Everett Chairman ACA Pension Schemes Committee Sent by to: Page 1 of 7

2 Section 75 Employer Debt in Non-Associated Multi-Employer Defined Benefit Pension Schemes Employer Debt in Non-Associated Multi-Employer Schemes 3.1 if we were to make any changes, should we exclude associated multiemployer schemes / limit the provision to multi-employer schemes? APPENDIX The primary purpose of the existing Employer Debt Regulations is to ensure the security of benefits for pension scheme members. This would suggest that, rather than a fundamental review, the purpose of any changes would be to address perceived inequalities in the current system, such as those suggested by non-associated employers of multi-employer schemes. Employers within associated multi-employer schemes are generally much more likely to be able to take advantage of the various easements available and as such are much less likely to be required to make payment of a Section 75 debt in full at the point of exit. Any restrictions would also depend on the definition of associated schemes. This is discussed further below. 3.2 if we were to exclude associated schemes / limit the provisions to nonassociated schemes, how could we best achieve this? As the consultation acknowledges there are difficulties in defining a non-associated multi-employer scheme and this is clearly key to being able to limit the extent of any changes made. We would suggest that the obvious starting point would be to make use of the definition of associated employer in Regulation 2(3A)(b) of the 2005 Employer Debt Regulations. The two possible definitions of a non-associated multi-employer scheme would then be: A scheme where none of the employers are associated as per the above definition; or A scheme where some (but not all) of the employers are associated. The choice of definition would then have some relevance to the answer to Question 3.1 above, in particular if the definition led to a requirement for none of the employers within a given scheme to be associated. Non-associated employers within a scheme that is deemed to be associated (by virtue of including some associated employers) may feel aggrieved at being unable to take advantage of any amendments that have been introduced. The definition would need to work for, for example, businesses that continue to participate in a scheme after being sold (on the assumption that such employers should not be treated as non-associated at the date of cessation if they were associated with the other employers of the scheme prior to the sale). Page 2 of 7

3 Once a definition of a non-associated multi-employer scheme has been determined it would then presumably be straightforward to achieve any necessary restrictions. Stakeholder views 4.1 has your organisation had any experience with the section 75 employer debt regime as it applies to non-associated multi-employer defined benefit schemes? Yes, members of our organisation represent a wide range of actuarial consultancy firms, the majority of whom will have advised a pension scheme in this position. 4.2 do you think that the employer debt regime for these schemes needs to be changed, or does it work as it currently stands? The answer to this question, which we take as being posed solely in relation to nonassociated schemes, will depend on the stakeholders being considered. The current regime broadly satisfies the objective to ensure the security of members benefits and therefore protect the PPF. The regime as it stands may drive employers into irrational behaviour. An example would be continued involvement in a defined benefit scheme beyond the point that it is affordable and/or consistent with wider strategy simply to avoid the payment of a section 75 debt. This is counter-intuitive in many cases as it could lead to a cash constrained employer continuing to offer defined benefit accrual in circumstances where the cost is unsupportable. This arguably decreases the security of member benefits. The current regime can appear illogical in some circumstances. For example in the case of an employer who has a large number of members in a multi-employer scheme, with very few remaining in active status. Such a situation may persist for many years, with the employer ultimately becoming liable for the section 75 debt based on a change in the status of a small number of members. As many pension schemes are now closed to new entrants the prevalence of such situations will inevitably increase. It would also be a benefit to many schemes if there were definitive guidance on what constitutes an active member for the purposes of determining whether an employmentcessation event has occurred, particularly with reference to the continuance of salary linkage and/or life cover. Existing easements designed to help employers manage employer debt 5.1 has your organisation had experience of these easements? How often have they been used? The most commonly used easements are those that involve apportioning debt to remaining employers and as highlighted in practice these are only applicable to associated schemes. However, rather than use the withdrawal or approved withdrawal arrangements mentioned in this section of the consultation document, schemes tend to use flexible apportionment arrangements. In our experience the use of the easements listed is relatively rare. It follows that the use of these easements by non-associated multi-employer schemes is also rare. Page 3 of 7

4 5.2 how effective are the easements for schemes and employers? For associated schemes, where employers can support each other in the recovery of debt payments our experience is that the easements work relatively well for all parties, although clearly they result in a smaller upfront payment to the scheme in most cases. However, as commented above the easements are less commonly used by nonassociated schemes and are therefore ineffective in managing debts for these schemes. 5.3 are there any weaknesses or problems with the current methods of managing employer debt? As noted above the easements are generally of little help to non-associated schemes. Also as noted in response to question 4.2 the current conditions under which debts are triggered do not lend themselves to effective management of employer debt. 5.4 could we make the easements easier to understand and use? No. In our experience use of the easements is now relative common amongst advisers and they are generally well understood. Clients would also generally be expected to take legal advice before proceeding in any case. Other suggested easements 6.1 do the current debt provisions for multi-employer schemes need to be amended, or could better use be made of existing easements to manage any problems any problems employers or schemes may face? We interpret this question as relating to non-associated schemes only. As highlighted in the answers above there is a distinct difference in the way that the current regime applies to associated and non-associated schemes. Our view is therefore that it would be appropriate to make changes to the relevant legislation in order to allow non-associated employers to benefit from a similar level of flexibility over debt repayments as associated employers. Flexibility around debt repayment 6.3 should DWP support and encourage greater flexibility regarding debt repayment plans? As highlighted by the submissions made to DWP such flexibility would certainly be welcomed by some stakeholders. However DWP clearly have a wider responsibility to ensure compatibility with the main aim of ensuring the security of members benefits. One benefit of greater flexibility not highlighted is the possibility of a greater recovery by allowing an employer to continue to trade, compared to potentially forcing them into insolvency following an employment-cessation event. The consultation comments on the risk of the scheme deficit fluctuating after the debt has been struck but before it has been paid in full. Whilst this seems likely in practice this Page 4 of 7

5 does not constitute a significant risk provided all parties are made aware of it. Under the current regime there can be a significant period between the date at which a debt is calculated and paid. It is also worth noting that unless the debt payment is invested in matching assets the corresponding deficit may still fluctuate. 6.4 how could any repayment plan recognise and balance the needs of employers and the scheme? The key requirement is for any flexibility to have a worthwhile impact on the employer whilst not impacting on the security of members benefits, allowing trustees to provide their agreement. Clearly the trustees would need detailed legal, actuarial and covenant advice before agreeing to such a proposal. Requiring the approval of the Pensions Regulator will focus trustees and employers on making a full assessment of the risks involved and proposing a workable solution. 6.5 would a longer timescale increase the risk of default? Are there ways that this risk could be mitigated? All other factors being equal a longer payment period would generally be expected to lead to a greater risk of default. The exception to this would be an employer close to insolvency, which may be able to provide a greater level of payments in the long term by being granted some leeway in the short term. The main way in which this risk can be mitigated is by taking professional covenant advice on the strength of the exiting employer and its ability to make payments in the future. In some circumstances a viable alternative may be to provide some sort of security to support the debt, such as a charge over an asset or a bank guarantee. We would anticipate that any payment schedule would be agreed in a legally binding document between the trustees and the exiting employer. Amend the provisions so that ceasing to employ active members does not trigger employer debt 6.7 what could the consequences and risks of making this change be for various stakeholders? Clearly relaxing the circumstances under which a debt becomes payable to the scheme would lead to less debts becoming payable under section 75 (at least in the short term) and as a result less payments to schemes. However, this may be beneficial in the longer term as it will allow employers to better manage their pension commitments over time. It will also allow employers to cease providing defined benefit pensions where these are no longer supportable. Page 5 of 7

6 As the payment of section 75 debts will generally reduce a scheme s funding deficit this change could also lead to an increase in costs to other employers. However, we would question this aspect of the current regime, which effectively forces exiting employers to subsidise the scheme for employers who remain to fund a scheme over the long term. One short-term consequence is likely to be a significant spike in the number of nonassociated employers choosing to cease accrual of benefits. There are two circumstances where this might occur: Where the employer is doing so simply to control costs. This may be detrimental to members. However the purpose of the Employer Debt Regulations is not to maintain the continued accrual of defined benefit pensions. Where the employer can no longer support the associated costs of accrual but maintained the arrangements simply to avoid the payment of a section 75 debt. This is arguably beneficial to all parties. If such a change is to be made then it is likely that there would be pressure for an equivalent change to be made for associated schemes. The logic behind changing the circumstances in which a debt is triggered affects all multi-employer schemes. 6.8 how could the relationship between a scheme and its non-active employers best be managed? The relationship can best be managed by ensuring the continued engagement of nonactive employers in the funding and management of the scheme. A significant proportion of UK pension schemes are now closed to future accrual of benefits and anecdotally there is little difference in engagement between their sponsors and sponsors of schemes open to future accrual of benefits. As long as the sponsor has a financial obligation towards the scheme we would anticipate that their engagement would continue. All participating employers of defined benefit schemes are subject to the Scheme Funding regime for as long as they remain as such. We suggest that rather than the Section 75 triggering when the scheme no longer has any active members, consideration is given to it triggering when the employer ceases to participate. The consultation specifically refers to the provision of adequate information with which to measure sponsor covenant. Pension scheme trustees are likely to take a less favourable view of the covenant provided by an employer that is unable or unwilling to provide adequate financial information. Hence there would be an incentive for non-active employers to do so, in order to control their funding obligations. 6.9 would a scheme s risk profile be affected, and if so how would this be managed? What could the consequences be? Fundamentally there is no immediate change in risk profile at the point a scheme closes to future accrual. The maturity of the scheme and the duration of future benefit payments do not change. We would not therefore expect immediate changes to funding or investment strategy. Page 6 of 7

7 We do recognise that over time there will be a slightly greater increase in the maturity of schemes with fewer active members. However, the vast majority of pension schemes are in a position where there maturity is expected to increase over time and this is reflected in their funding and investment strategy. Change the way liability is calculated following an employment-cessation event 6.11 are there any other ways in which an employer s covenant strength could be assessed and liability could be calculated? In our view the most appropriate way to assess an employer s covenant would be to obtain information from the company itself and employ a specialist adviser. This is even more the case where the assessment will lead to the level of debt that is levied on exit. In circumstances such as this we would anticipate that the exiting employer would have a vested interest in providing comprehensive and up to date information on its covenant as the consequences of not doing so would presumably be for the trustees to seek further payments. Our view would be that once the covenant has been assessed then the best way to assess the appropriate level of payment would be for the trustees to work with their advisers. However, we would acknowledge the role of the Pensions Regulator in overseeing this process and providing additional guidance where appropriate what could the consequences and risks of making this change be for various stakeholders? The risks of this approach are very much the same as those set out in the response to question 6.7. This is because both arrangements effectively allow an employer to continue to meet its funding obligations in the short term, rather than pay a full section 75 debt. About the Association of Consulting Actuaries (ACA) Members of the ACA provide advice to thousands of pension schemes, including most of the country s largest schemes. Members of the Association are all qualified actuaries and all actuarial advice given is subject to the Actuaries Code. Advice given to clients is independent and impartial. ACA members include the scheme actuaries to schemes covering the majority of members of private sector defined benefit pension schemes. The ACA is the representative body for UK consulting actuaries, whilst the Institute and Faculty of Actuaries is the professional body. Regis House First Floor 45 King William Street London EC4R 9AN Tel: Web: 22 May 2015 Page 7 of 7

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