State Universities Retirement System of Illinois

Transcription

1 State Universities Retirement System of Illinois Serving Illinois Community Colleges and Universities 1901 Fox Drive Champaign, IL (217) (217) (FAX) Investment Department To: Investment Committee From: Daniel L. Allen, Lou Ann Fillingham, CPA, and Gabriel Ayoroa, CFA Date: December 2, 2013 Re: Annual Review of Minority-, Female- and Persons with a Disability- Owned Broker/Dealer Usage by SURS Investment Managers SURS implemented a brokerage usage policy upon its approval as a component of the Investment Policy at the December 9, 2005, Board of Trustees meeting. Revisions were approved annually by the Board beginning in 2007, providing further modifications regarding brokerage expectations. Standard investment reports prepared quarterly for the Board include brokerage cost reviews by asset class that summarize the total usage of minority-, female- and persons with a disability- owned (MFDB) brokerage firms over the prior four quarters by investment managers in SURS defined benefit portfolio. An annual review is presented to the Board of Trustees highlighting results for the previous fiscal year and identifying investment managers facing challenges in attaining the established expectation levels over the previous fiscal year. Based on information included in the quarterly and annual reviews, investment managers may be invited to participate in a presentation to the Board to assist in explaining current issues regarding brokerage compliance. Ultimately, an investment manager that is continually unable to attain the expected level of usage of MFDB firms may be placed on SURS Watch List and potentially terminated. In 2013, one manager was terminated due to the continued inability to achieve the expected level of utilization of MFDB firms. Fiscal Year 2013 Results SURS Summary Goals Utilization of Minority-, Female- and Persons with a Disability- Owned Broker/Dealer Firms Asset Class Goal U.S. Equity 30.0% Non-U.S. Equity 15.0% Fixed Income 20.0% The table above lists the minority-, female- and persons with a disability- owned brokerage goals by asset class included in SURS Investment Policy, as approved at the Board Meeting on September 13, The summary table on the following page indicates that in the four previous fiscal years, total commissions paid by SURS equity investment managers declined from 2010 through 2012 and increased during 2013 while utilization of MFDB brokerage firms steadily increased.

2 Equity Commissions Summary Results Total Commissions Actual MFDB Fiscal Year Commissions * to MFDB Firms Utilization 2010 $ 5,081,540 $ 1,622, % 2011 $ 4,299,700 $ 1,483, % 2012 $ 3,871,797 $ 1,556, % 2013 $ 4,022,175 $ 1,658, % * Total commissions exclude electronic trades and emerging market trades. The following table summarizes the level of trading with MFDB broker/dealers in each of the major asset classes for the year ending June 30, Trading with Minority-, Female- and Persons with a Disability- Owned Broker/Dealer Firms Year Ending June 30, 2013 Commissions Actual MFDB Asset Class to MFDB Firms Utilization Goal Variance U.S. Equity, Active $ 481, % 30.00% 10.64% U.S. Equity, Passive 1 $ 4, % 35.00% 65.00% U.S. Equity, Enhanced Active 95, % 10.00% 35.52% U.S. Equity, Total $ 581, % 30.00% 11.56% Non-U.S. Equity, Active $ 528, % 15.00% 34.59% Non-U.S. Equity, Enhanced Active 90, % 10.00% 8.02% Non-U.S. Equity, Total $ 619, % 15.00% 24.45% Global Equity $ 389, % 17.50% 21.36% REITs 2 $ 68, % 10.00% 13.11% Total Equity $ 1,658, % Fixed Income 3 N/A 29.37% 20.00% 9.37% TIPS 3 N/A 23.62% 10.00% 13.62% 1 Six month period, January 1 through June 30, Domestic REITs and global REITs, combined. 3 Commissions are not applicable to fixed income. Percentage calculation is based on percent of total market value traded with MFDB firms. For the one-year period ending June 30, 2013, commissions totaled $5.45 million on equity trades. As the table above indicates, commissions to MFDB broker/dealers were approximately $1.66 million, representing 38.9% of total commissions paid on equity trades for the period. In aggregate, all asset classes exceeded the brokerage goals set forth in the Investment Policy for trading with minority-, female- and persons with a disability- owned firms. As a component of the annual compliance process, SURS staff communicates with each of the investment managers, reminding them of SURS commitment to the initiative adopted by the Board at the March 19, 2004 meeting. This initiative was created to develop a strategy for

3 increasing the utilization of minority- and women-owned broker/dealers. Since January 2006, SURS has been formally communicating quarterly with investment managers who are not achieving the desired levels of utilization. The evaluation is based on a rolling four-quarter period. Due to the inherent seasonality embedded in the reporting process, managers may occasionally fall below levels of utilization for truncated periods of time while consistently reaching overall utilization goals over the longer term. SURS domestic equity, non-u.s. equity, global equity and REIT managers submit brokerage information quarterly that is reconciled to data provided by SURS custodian, Northern Trust. Managers Not Achieving Desired Expectation Levels For the rolling four-quarter periods ended during fiscal year 2013, the level of MFDB usage achieved by the following three investment managers was below the levels established by SURS. Asset Class Investment Manager 12-Month Period End Utilization Goal Actual MFDB Utilization Global Equity T. Rowe Price 3/31/ % 16.43% Global Equity T. Rowe Price 6/30/ % 17.43% REITs RREEF 9/30/ % 7.99% Fixed Income State Street Global Advisors 6/30/ % 16.33% Each manager not achieving the minimum level of minority-owned broker/dealer usage for a rolling four-quarter period in fiscal year 2013 received a letter reminding them of the usage expected by SURS. Discussions are ongoing between SURS staff and these managers to understand and resolve the reasons for failure to achieve the expected utilization levels. Aberdeen Asset Management (Aberdeen) began managing a global equity portfolio for SURS in August 2008 and initially complied with the brokerage policy, exceeding the minimum expectations on a regular basis. However, in January 2011, the policy was modified to require direct execution rather than indirect execution while still attaining best execution. Aberdeen found it difficult to comply with the revised policy since the firm has a global trading policy that applies to all clients, and, as such, could not be tailored for individual client requests. Compliance with the SURS Brokerage Policy was the lone area of discontent with the firm. SURS has maintained a longstanding commitment to diversity and utilization of minority brokerage goals, which was communicated accordingly to the firm. The situation could not be resolved and, as a result, the relationship with Aberdeen was terminated in fiscal year SURS Monitoring Process During fiscal year 2013, staff visited and communicated with the investment managers not meeting the desired usage levels of MFDB broker/dealers. Letters of non-compliance were sent to the three managers listed above with a response requested that was to address the reason(s) for not attaining the expected level of MFDB utilization. All managers are aware of the importance of the initiative as well as the goals set forth in the Investment Policy, with some acknowledging challenges in achieving both best execution and the established MFDB utilization levels. The September 2010 revision to the Investment Policy that allows credit only for direct, rather than indirect, trading with MFDB firms has proven challenging for several non-u.s. and global equity managers. Because the universe of MFDB firms capable of providing direct international trade execution at competitive rates is relatively small at this time, some investment managers have been unable, in the short term, to meet expectations.

4 Staff is regularly communicating with managers in an effort to achieve the goals without compromising best execution. When selecting a broker, the manager must consider many factors, including achieving best price, commission rate, liquidity and willingness to commit capital, trade flow, transaction size, confidentiality, technology infrastructure, operational capabilities, broker research, expertise in particular markets and use of local desks in global markets. Compliance Enforcement Measures Included in Appendix 2 and as stated in section XVI(B) of SURS Investment Policy adopted by the Board of Trustees on September 13, 2013, an investment manager will be subject to the following sequence of events when continuing to fall short of attaining the desired level of MFDB broker/dealer utilization: 1) A follow-up letter will be distributed to the investment manager not achieving the minimum level of minority-owned broker/dealer usage. The investment manager will be reminded of the usage expected by SURS. Currently, as stated in the Annual Report to the Governor and General Assembly on the Use of Emerging Investment Managers, prepared as required in Public Act , a letter is distributed to all of the investment managers on an annual basis listing the level of expectations. 2) Not achieving the desired level of minority-owned broker/dealer usage will be noted in the annual investment manager review presented to the SURS Board of Trustees. This could impact the evaluation of the firm. 3) SURS Staff will conduct a meeting with the investment manager to discuss the reasons for not achieving the desired level of trading. 4) Investment managers not achieving the expected levels of broker/dealer usage may be subject to a moratorium on additional funding. 5) If an investment manager fails to comply with the request, they may be invited to appear before the SURS Board of Trustees to explain why they are unable to achieve the desired level of trading. 6) The investment manager may be placed on the Investment Manager Watch List in accordance with section IX of this policy. SURS On-line Brokerage Reporting System An on-line brokerage reporting system, developed by SURS staff in 2010, has been used by investment managers since the first quarter of calendar year 2011 to enter quarterly data. Staff uses information in the system to complete various reports, including quarterly brokerage cost reviews, annual reports of the utilization of the Chicago Stock Exchange, and the annual utilization of Illinois broker/dealers. The data in the system is available for ad hoc purposes as well. The system has provided significant time savings for staff by eliminating cumbersome, labor-intensive tasks involved in reconciling, recording and reporting brokerage information. Additional annual cost savings were realized by eliminating the need for a $35,000 contract to monitor and report manager utilization of the Chicago Stock Exchange. The system is enhanced to address specific needs as they arise.

5 Summary Appendix 1 includes a comparison of SURS desired usage levels of MFDB broker/dealer firms versus other Illinois large public pension funds. Appendix 2 lists the brokerage expectation levels stated in the Investment Policy approved by SURS Board on September 13, Staff knowledge regarding the brokerage oversight function continues to expand. SURS does not specify the broker/dealers to be used by investment managers; however, when SURS becomes aware of a MFDB broker/dealer, the firm s information is shared with SURS investment managers. The investment managers are expected to communicate with the prospective broker/dealer firm to assess the feasibility of establishing a relationship. SURS has increased awareness of the brokerage community as a result of the Board initiative and the Senate Pensions and Investments Committee hearings. Staff will continue to monitor investment manager utilization of MFDB broker/dealers on a quarterly basis. In addition, staff will continue to encourage managers to enhance efforts in achieving the expected levels of direct trading with MFDB broker/dealers while maintaining best execution practices.

6 Appendix 1 Minority-, Female- and Persons with a Disability- Owned Broker/Dealer Usage Expectation Levels October 2013 Teachers Retirement System of Illinois (TRS) Domestic Equity 18% International Equity 12% Fixed Income (based on volume) 15% Illinois Municipal Retirement Fund (IMRF) (All trade levels must be directly executed) Domestic and International Equities, Fixed Income 20% Domestic Micro-Cap Equities, International Small-Cap Equities, Emerging Market Equities and High Yield 5% State Universities Retirement System (SURS) (All trade levels must be directly executed) Active U.S. Equity Separate Accounts 30% Passive U.S. Equity Separate Accounts 35% Structured Active Domestic Equity Separate Accounts 10% Non-U.S. Equity Separate Accounts 15% Structured Active Non-U.S. Equity Separate Accounts 10% Global Equity Separate Accounts 17.5% Fixed Income Separate Accounts 20% Real Estate Investment Trusts (REITS) & Treasury Inflation-Protected Securities (TIPS) 10% Illinois State Board of Investment (ISBI) Domestic Equity 30% International Equity 20% Fixed Income 20% International Fixed Income and Emerging Market Small Cap Equity 0-5% Public School Teachers' Pension & Retirement Fund of Chicago (CTPF) (All trade levels must be directly executed unless otherwise noted) Active Domestic All-Cap, Large-Cap and Mid-Cap Equity 50% Active Domestic Small-Cap Equity 35% Passive Large-Cap Equity 35% International Equity 25% Fixed Income (based on volume) 25% County Employees' Annuity & Benefit Fund of Cook County Domestic Equity 35% International Equity 10% International Small Cap and Emerging Market Equity 3% Fixed Income (based on volume) 10% Municipal Employees' Annuity and Benefit Fund of Chicago Domestic Equity 40% International Equity 20% Fixed Income (based on volume) 25%

7 Appendix 2 State Universities Retirement System of Illinois Minority-Owned Broker/Dealer Usage Policy 1 Section XVI(B) of SURS Investment Policy (9/13) The Board of Trustees of the State Universities Retirement System has an established policy that seeks increased participation of investment management firms owned by minorities, females, and persons with a disability. As part of this policy, the Board also adopts minimum expectations for the use of minority-owned broker/dealers 1 by the System s investment managers. Only trades executed directly with minority-owned broker/dealers will be considered in the achievement of these goals. Summary goals for the utilization of minority-owned broker/dealers have been established for the aggregate U.S. equity, non-u.s. equity and fixed income asset classes as shown in the table below. SURS seeks to consistently exceed these high level goals while achieving best execution. Asset Class Goal U.S. Equity 30.0% Non-U.S. Equity 15.0% Fixed Income 20.0% In order to achieve the goals at the asset class level, minimum expectations have been established for individual investment managers. These levels are based on the asset class in which the investment manager invests. SURS encourages its investment managers to strive to exceed the minimum expectations shown in the table that follows. Asset Class Minimum Expectation EQUITY Active U.S. Equity 30.0% Passive U.S. Equity 35.0% Structured Active U.S. Equity 10.0% Non-U.S. Equity 15.0% Structured Active Non-U.S. Equity 10.0% Global Equity 17.5% Real Estate Investment Trusts (REITS) 10.0% FIXED INCOME Fixed Income 20.0% Treasury Inflation-Protected Securities (TIPS) 10.0% 1 For purposes of this section and in accordance with P.A , minority-owned broker dealer means a qualified broker-dealer who meets the definition of minority owned business, female owned business, or business owned by a person with a disability, as those terms are defined in the Business Enterprise for Minorities Females, and Persons with Disabilities Act.

8 U.S. Equity Separate Accounts Subject to best execution, active U.S. equity investment managers for SURS are required to direct 30% of the total eligible commission dollars to minority-owned broker/dealers. Trades executed using electronic trading platforms are excluded from this requirement. Subject to best execution, passive U.S. equity investment managers for SURS are required to direct 35% of the total eligible commission dollars to minority-owned broker/dealers, effective January 1, Trades executed using electronic trading platforms are excluded from this requirement. Structured Active U.S. Equity Separate Accounts Subject to best execution, structured active U.S. equity investment managers for SURS are required to direct 10% of the total eligible commission dollars or eligible trading volume to minority-owned broker/dealers. Trades executed using electronic trading platforms are excluded from the 10% requirement. Non-U. S. Equity Separate Accounts Subject to best execution, active non-u.s. equity investment managers for SURS are required to direct 15.0% of the total eligible commission dollars to minority-owned broker/dealers. 2 Trades executed in emerging market countries 3 or using electronic trading platforms are excluded from this requirement. Structured Active Non-U.S. Equity Separate Accounts Subject to best execution, structured active non-u.s. equity investment managers for SURS are required to direct 10% of the total eligible commission dollars or eligible trading volume to minority-owned broker/dealers. Trades executed in emerging market countries or using electronic trading platforms are excluded from the 10% requirement. Global Equity Separate Accounts Subject to best execution, active global equity investment managers for SURS are required to direct 17.5% of the total eligible commission dollars to minority-owned broker/dealers. Trades executed in emerging market countries or using electronic trading platforms are excluded from the 17.5% requirement. Fixed Income Separate Accounts Subject to best execution, fixed income investment managers for SURS are required to direct 20% of eligible fixed income trading volume to minority-owned broker/dealers. Trades executed in emerging market countries or using electronic trading platforms are excluded from the minimum trading requirements. Treasury Inflation-Protected Securities (TIPS) Separate Accounts Subject to best execution, active TIPS investment managers for SURS are required to direct 10% of eligible TIPS trading volume to minority-owned broker/dealers. Trades executed in emerging market countries or using electronic trading platforms are excluded from the minimum trading requirements. 2 The minimum expectation for non-u.s. equity investment managers increased from 12.5% to 15.0%, effective January 1, As defined by Morgan Stanley Capital International

9 Real Estate Investment Trust Securities (REITS) Separate Accounts Subject to best execution, active REITS investment managers for SURS are required to direct 10% of the total eligible commission dollars to minority-owned broker/dealers. Trades executed in emerging market countries or using electronic trading platforms are excluded from this requirement. Reporting Guidelines Each investment manager will submit a compliance report within 30 days after March 31, June 30, September 30 and December 31 of each year. Reporting will be monitored over a rolling twelve-month period. Consequences of Non-Compliance SURS continuously monitors investment managers compliance with this policy and has established a series of consequences for those investment managers who continually fail to meet expectations. The investment managers are expected to achieve the desired levels over rolling twelve-month periods. The following steps will occur if the investment manager continues to fall short of expectations: 1) A follow-up letter will be distributed to the investment manager not achieving the minimum level of minority-owned broker/dealer usage. The investment manager will be reminded of the usage expected by SURS. Currently, as stated in the Annual Report to the Governor and General Assembly on the Use of Emerging Investment Managers, prepared as required in Public Act , a letter is distributed to all of the investment managers on an annual basis listing the level of expectations. 2) Not achieving the desired level of minority-owned broker/dealer usage will be noted in the annual investment manager review presented to the SURS Board of Trustees. This could impact the evaluation of the firm. 3) SURS Staff will conduct a meeting with the investment manager to discuss the reasons for not achieving the desired level of trading. 4) Investment managers not achieving the expected levels of broker/dealer usage may be subject to a moratorium on additional funding. 5) If an investment manager fails to comply with the request, they may be invited to appear before the SURS Board of Trustees to explain why they are unable to achieve the desired level of trading. 6) The investment manager may be placed on the Investment Manager Watch List in accordance with section IX of this policy.