Steve Webb, the pensions minister, thinks we only have 12 months to save DB but that, in its current form, it might be like trying to apply electrodes to a corpse. Unfortunately his prescription – Defined Ambition (DA) – is still very much undefined and therefore, as yet, unambitious.

Pension active membership

Number of members of private sector occupational pension schemes: by membership type and benefit structure, 2004-11

Source: Office of National Statistics

The graph above shows how dramatic the decline of DB active membership (ie members still accruing benefits in defined benefit schemes which provide a pension defined in advance, where the balance of funding is committed to by the employer in nearly all cases) has been in recent years. It also shows, contrary to some reports, that there has been no advance in DC active membership (ie defined contribution schemes where only the contributions are defined in advance and final benefits are at the mercy of financial markets and annuity rates). It just hasn’t fallen much. In fact, if all of the DC active members had instead been offered DB active membership, the number of DB active members would still have fallen.

So it is a crisis and it appears to be those who are opting for no pension scheme at all who are really growing in number. The auto-enrolment programme starting to be rolled out across the country will have an impact, after all if you keep asking the question and don’t take no for an answer you will attract customers – just ask the banks who were selling PPI cover.

But I wonder if the crowd avoiding pensions of any sort up until now might perhaps have more wisdom than those trying to pile them into schemes whether they want to or not. Because DC has to date been a very poor offer for most, with very low levels of contributions. The latest survey by the ONS of households between 2008 and 2010 where the primary earners are between 50 and 64 revealed that median pension savings in DB schemes were equivalent to around six times those in DC schemes. And the minimum contributions under auto-enrolment of 8% of qualifying earnings from all sources with all risks staying with the member is unlikely to change this massive inequality quickly if at all.

If you have very little money, and the pension option means that your pension contributions are likely to be bounced around by the markets for a few decades before dribbling out in whatever exchange the insurance companies are prepared to give you, is it irrational to think that you might want to keep some access to your savings along the way? The following graph suggests most people don’t think so.

Decile savings

Breakdown of aggregate saving, where household head is aged 50 to 64: by deciles and components, 2008/10

Source: Office of National Statistics

This graph suggests that people do save for a pension where they can, but if there is not much to go round, they also want some more liquid savings. The problem is not that they are not saving for a pension, it is that they have no assets at all.

So what is to be done? Clearly campaigning for a living wage needs to continue and be intensified, and reductions to benefits are going to make the problem worse. But fiddling around with marginally different forms of DC arrangements for decades will also be disastrous. Think not just a few naked pensioners on the beach as we had before the Pension Protection Fund (PPF) came in for DB members. Think armies of them with a genuine grievance against a society that did this to them. And what will have been done to them is to suggest that by paying 4% of their salary into a pension scheme, they have somehow safeguarded their future. Good employers are not going to want to be associated with scenes (or schemes) like this.

DC contributions need to be much higher while they remain so risky, which is why DB schemes target asset levels much higher than their best estimate of the cost in most cases, but clearly DB levels are too high for nearly all employers. There is not much time, as Steve Webb says, so let’s stop messing around and pick an alternative.

I vote for cash balance (CB). There are many different sorts but the feature they all have in common is a defined cash sum available at retirement which members can then take in a combination of lump sum, annuity and drawdown (ie keeping the sum in the scheme and drawing income from it as needed). It means that the bumping around by the markets is taken on the chin by your employer not you, but only until retirement (the type of risk employers are used to managing in their businesses anyway), and the risk of you living longer (reflected in lower annuity rates) when you get to retirement is your problem. It seems reasonable to me. Whoever thought that an employer should be concerned with how long you are going to live (unless they were the mafia)? Good employers could also offer a broking service for annuity purchase to avoid the problem of pensioners not shopping around adequately.

There are a few of these in existence already, although only 8,000 members in total benefit from them so far. In the case of Morrisons, the guarantee is 16% of salary a year, uprated in line with CPI. This is one of the current minimum levels to be accepted as an auto-enrolment plan. Alternatively you could drop to 8% a year, but uprate it by CPI plus 3.5% pa. Either would be a huge improvement for someone with limited means to relying on what 8% of earnings pa might amount to in 40 years’ time, and unable to take the risk that the answer is not much.

But the first step is to establish CB as what is meant by DA and that will need Government support to work. I propose:

  • CB to be promoted as one of the main options for an auto-enrolment scheme, equivalent to the 8% minimum but without total risk transfer to the employee.
  •  Develop a colour coding scheme for a combination of benefit level and risk transfer, with DC at minimum auto-enrolment at the red end, minimum CB at amber running through green to the equivalent of a public sector DB scheme or better as (NHS) blue.
  • Sort out the PPF position on CB. They currently treat them as full DB schemes. Scale down PPF levies to reflect the lower level of risk that they present to the PPF.
  • Simplify the pensions legislation around CB to reflect the fact that the scheme’s responsibility for managing risk ends at retirement.

And we really need to start now!

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The people in power have no real belief that Plan A will work but refuse to even consider there might be a Plan B. They occupy themselves and the surrounding elite class bubble in which they operate with trivial concerns played out as if they were life and death ones, and the rest of the population are pacified with horse tranquilisers muscle relaxant.

Sound familiar? There is also inevitably a banker involved and someone who cannot stop herself from making dire predictions which her fellow travellers cannot prevent themselves from taking seriously.

Pedro Almodovar has come in for a fair amount of criticism for the perceived shallowness of his latest film Los Amantes Pasajeros (presented as “I’m So Excited” in English due to the prominence of the Pointer Sisters’ song in the film, but more literally translated as the on board or passing lovers). However what came to mind most strongly for me when watching it was Bismarck’s famous comparison between the making of laws and sausages (ie not a pretty sight). And indeed quite a few sausages are “made” during this film, under the influence of a “Valencia cocktail” with added mescaline, as all efforts are concentrated on sleepwalking to the planned emergency landing at an as yet unavailable airport in as pleasantly mindless a way as possible.

An economic policy in which only a tiny minority have any idea what is going on and only a tiny minority of that tiny minority feel able to influence what is going on in the cockpit is a shallow one. Perhaps we all need to get a bit more excited.

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There has been much discussion over the past few months over whether high levels of debt cause low growth (the “austerian” camp, eg Britain, Canada and Germany within the G7) or whether instead low growth causes high levels of debt to accumulate (the “Keynesian” camp, to which Japan appears to be providing leadership currently). There has been relatively little discussion about the possibility that neither is the case.

We are compulsive pattern spotters. That explains to a large extent our dominance as a species, and completely explains the dominant position that mathematics and its applications holds in our culture.

I was reminded most stirringly of this a few years ago, on a lunch break. The Ikon Gallery in Birmingham was hosting an exhibition by Japanese sound artist Yukio Fujimoto called The Tower of Time. However, instead of siting it at their gallery space in Brindley Place, it had instead been staged at Perrott’s Folly, just around the corner from my office at the time.

Yukio Fujimoto. The Tower of Time
Installation view – Perrott’s Folly, Birmingham, UK 2009  Photo: Stuart Whipps

Perrott’s Folly was built in 1758 by John Perrott. It is a building 94 feet high, with one room on each of its six octagonal floors, and no obvious purpose (hence “folly”). It may have been somewhere to spy on his wife from, while she was alive or dead, or it may have been a gambling den for him and his mates. Or it may have been something else entirely. I think we are unlikely to ever know for sure.

After a brief introduction on the ground floor, I climbed the stairs to the first floor to find one little black square alarm clock with a red second hand ticking in the middle of the wooden floor. The next floor had ten such clocks, in a row. The next 100, in a square, the fifth floor had 1,000.

A curious thing happened to me as I moved up the tower. The clocks’ mechanisms appeared to alter with altitude. I put it that way as an example of an obviously false causality, ie that the height above sea level in some way affected how the clocks worked (and before I get complaints, I mean effects that could be detected within a matter of a few tens of feet and with no measuring equipment other than my eyes and ears). Because what I saw did change. I looked at one clock and I could see that the battery was powering the gear mechanism that kept the second hand, minute hand and hour hand in their required relative motion. I looked at ten clocks in a row and I could see the same, although I also noticed the second hands were not all at the same point along the row and that there was an order in which each piece of red plastic reached the top before beginning the next circuit. I found myself having to watch the clocks for several minutes to see the pattern confirmed. But was this “pattern” anything which had any meaning, or was it just a way for my brain to store the images it was collecting in an easily fileable format?

When I moved to 100 clocks, the relevance of the gear mechanism became secondary. I could “see” lines of second hands moving together in the way that lines of plants in a cornfield move with the breeze. This, combined with the swooshing of 100 clocks (as the ticking of each individual clock combined to make a different noise – this change in sound was I believe the artist’s main reason for constructing the installation in the first place), made me need to check several times that one of the strange pointed windows in the tower had not been opened and let in a stray breeze. At 1,000 clocks it was just pure cornfield, the individual clocks now as hard to imagine as it had been to imagine anything else four floors below.

I can “see” that the “wind” is blowing a pattern through the second hands of the clocks and yet I “know” that this is not happening. Now transfer that wind I can see to a situation where I do not readily have a theory for what is happening to individual elements within a system. Suddenly what anyone with eyes can see becomes so much more powerful than what we might know. Returning to the austerity debate for instance, perhaps the individual growth clocks have no relationship with the patterns of debt I can see being blown through them. Perhaps if I just arranged the clocks differently I would see the wind blowing from a different direction. Perhaps the clocks and the wind have nothing to do with each other outside my head, despite the “evidence” of my eyes.

Why does it matter? Because if we cannot prevent ourselves from seeing patterns and then extending them via models where we have to make some things depend on other things, even in the face of weak and conflicting evidence, then we need to know this about ourselves. Because if giving a person the wrong map is worse than not giving him one at all, our natural instinct to construct these maps is likely to keep getting us into trouble.

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The interests of the UK’s private sector defined benefit (DB) pension scheme members, and the security of their vested benefits (ie the ones they are entitled to keep), were weakened this week. The Pensions Regulator, slow to act in many cases, bureaucratic and inconsistent in others, did at least have a coherent set of objectives which allowed it to focus on reducing the fragility of the pensions system overall. However this is not an example of how the Government wants its regulators to behave it seems. The announcement in the Budget in March that the Regulator is to get an additional statutory objective to encourage “sustainable growth” amongst scheme sponsors, following sustained lobbying from the National Association of Pension Funds and the Confederation of British Industry, led to a swift consultation on, and acceptance of, the proposals. It also appears to have led to an equally swift exit for the Regulator’s chief executive Bill Galvin (he leaves next month) who had had dared to reject calls for such an objective, pointing out reasonably that the existing arrangements required the Regulator and trustees to balance the interests of business, the pension scheme and the Pension Protection Fund.

So here it is, the Pensions Regulator’s first statement on DB pension schemes since the new objective was announced. The Regulator looks to have been very mindful of the not-yet-quite-existing objective in framing this statement and, although the precise wording of the objective is not expected until later in the year, has obviously already decided which way the wind is blowing. The key word that jumps out at you on a first skim is “flexibility”, which seems to be the new code for weakening regulation now that “light touch” has been discredited. This contrasts with last year’s statement, when the use of the word was accompanied by a warning that “we will consider whether the flexibility in the funding framework has been used appropriately”, ie emphasising the limits of flexibility rather than its possibilities.

There are also a number of areas where the position taken by the Regulator on funding appears to have noticeably weakened since 12 months ago. Here, in my view, are some of the main ones (italics are mine):


Pension scheme funding in the current environment – April 2012


Defined benefit annual funding statement – May 2013


In the regulator’s view, investment outperformance should be measured relative to the kind of near-risk free return that would be assumed were the scheme to adopt a substantially hedged investment strategy.


Trustees can use the flexibility available in setting the discount rates for technical provisions…to adopt an approach that best suits the individual characteristics of their scheme and employer.

19, 14

The regulator views any increase in the asset outperformance assumed in the discount rate to reflect perceived market conditions as an increase in the reliance on the employer’s covenant. Therefore, we will expect trustees to have examined the additional risk implications for members and be convinced that the employer could realistically support any higher level of contributions required if the actual investment return falls short of that assumed.

Where appropriate the use of actual post valuation experience is acceptable.



The assumptions made for the relative returns of different asset classes may rise or fall from preceding valuations reflecting changes in market conditions and the outlook for future returns. Trustees should ensure that they document their reasons for change and have due consideration to any increase in risk this might bring.


As a starting point, we expect the current level of de­ficit repair contributions to be maintained in real terms, unless there is a demonstrable change in the employer’s ability to meet them.



Where there are significant affordability issues trustees may need to consider whether it is appropriate to agree lower contributions and this may also include a longer recovery plan. Trustees should ensure that they document the reasons for any change and indicated that they have had due consideration of the risks.

Finally, under the heading what you can expect from us, the Regulator also mentions that it has discarded any triggers it had for subjecting schemes to further scrutiny “on individual items such as technical provisions”.

Unfortunately the combined impact of the changes in emphasis, specific wording and the ditching of the triggers would appear to directly conflict with two of the Pensions Regulator’s definitely-still-existing objectives, namely:

  • to protect the benefits under occupational pension schemes of, or in respect of, members of such schemes; and
  • to reduce the risk of situations arising which may lead to compensation being payable from the Pension Protection Fund.

The House of Lords Select Committee on Regulators in 2007 concluded that:

  • Independent regulators’ statutory remits should be comprised of limited, clearly set out duties and that the statutes should give a clear steer to the regulators on how those duties should be prioritised.
  • Government should be careful not to offload political policy issues onto unelected regulators.

We will have to wait and see exactly where this new objective is to be pitched, but, on the evidence of this funding statement from the Regulator, there must now be considerable doubt that either of the select committee principles will be met.

Set any organisation conflicting objectives and no clear way of prioritising between them and the chances are they won’t achieve any of them. The Pensions Regulator has already started to run this risk.

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