The consultation on the future shape of workplace pensions has been going on for nearly a month now and ends two weeks on Friday. It is littered with errors, from completely repeated questions (Q52 = Q54) to ones which are so similar as makes no difference (Qs 41 and 44 for example) and the thrust of a lot of the questions are quite hard to answer if you do not share some of the underlying assumptions of the DWP about the process, but come on! This is our chance to put a bit of definition into the rather blurry outline of a straw man which some of the newspapers have been tilting at so vigorously!

You don’t have to answer all of the questions, but just to goad you a bit I have done so here. Agree, disagree, I would love to hear from you. But not until you have responded to one of the following addresses:

How to respond to this consultation

Pleasesendyourconsultationresponses,preferablybye-mail,to:definedambition.pensionsconsultation@dwp.gsi.gov.uk

Or by post to:

Defined Ambition Team

Private Pensions Policy and Analysis

1st Floor, Caxton House

6-12 Tothill Street

London

SW1H 9NA

 

Feedback on the consultation process

There have only been 24 posts on the blog. I think the main reason for this was identified early in the process from a contributor referring to herself only as Hannah:

Hannah

I applaud the use of an open blog but it’s obvious that there’s a bit of a problem here! Perhaps, to avoid this becoming sidetracked, you could introduce a drop-down in the comment section so that people could select what aspect of DA reform or the consultation their comment relates to – and if their comment relates instead to concerns about their accrued benefits, you could redirect them to a separate specialised member queries page?

Reply

Sam Gilbert

Thanks for this Hannah, we will look into this once the blog picks up pace.

DA Team, DWP

Of course the blog never did pick up pace because people soon realised that there comments would be lost in a stream of pension benefit queries. Not the way to encourage a consultation. If you want to comment on this or anything else about the process of the consultation, the contact details are as follows:

Elias Koufou

DWP Consultation Coordinator

2nd Floor

Caxton House

Tothill Street

London

SW1H 9NA

Phone: 020 7449 7439

Email:elias.koufou@dwp.gsi.gov.uk

20131126_122758I received a set of nontransitive dice in the post this week. Transitive is an interesting word. As we all know in grammar it refers to verbs which do things to something. What I didn’t learn at school was that if they do things to one thing they are called monotransitive, and ditransitive if they have both a direct and indirect object. A verb like to trade is categorised as tritransitive. If a verb does not play with others it is called intransitive, eg an example appropriate to this story, to die. If a verb swings both ways it is called ambitransitive.

In the mathematical world transitive is a description of a relation on a set. For example, if A = B and B = C, then A = C. So = is transitive. Similarly, if A > B  and  B > C  then  A > C.

Or does it? Let’s return to the dice (singular die: cemented in my memory on the occasion a teacher responded to a boy coming into his class and asking to borrow a dice by shouting “die, die, die!” at the startled youngster). Mathematicians do not use the word intransitive, preferring perhaps to avoid the ambiguity of words like flammable and inflammable, but instead use nontransitive. Nontransitive dice have the property that if die A tends to beat die B on average, and die B tends to beat die C on average, then rather counter-intuitively die C tends to beat die A on average. How does this work?

There are many different arrangements of the numbers on the faces of the dice which would achieve this effect. My red die has 4 on all its faces except one, which has a 6. My blue die has half its faces with 2s and the other half with 6s. My green die has 5 on all its faces except one, which is unnumbered (or, in fact, undotted).

If we take the average number we expect to get when throwing each die (the concept of expected value, first introduced by Blaise Pascal of triangle fame, also known as the mean, is the first thing that tends to get calculated in any statistical analysis), then red gives us 4⅓, blue gives us 4 and  green     4 1/6. So we would expect from that to see red beat blue, green beat blue and red beat green.

When we pitch red against blue, if we throw a 2 with the blue die (probability of a ½), then we will always lose to red, since all of its faces are greater than 2. If we throw a 6 with blue, we have a 5/6 chance of beating red (since 5 of its 6 faces are 4s) and a 1/6 chance of drawing. So we have for blue a probability of ½ of losing, a probability of ½ x 5/6 = 5/12 of winning and a probability of ½ x 1/6 = 1/12 of drawing. So, in the long run, red beats blue on average, as we would expect it to.

When we pitch blue against green, blue will always win if we throw a 6 with it, with a probability ½. If we throw a 2, also with a probability ½, we have a 1/6 chance of winning against green (if green’s single blank face comes up) otherwise we will lose to a 5. So we have for blue a probability of losing of ½ x 5/6 = 5/12. And the probability of winning as blue (since no draws are possible this time) of 1 – 5/12 = 7/12. So, in the long run, blue beats green, exactly the opposite of what we would expect just going on the expected values.

Finally, when we pitch red against green, the only time green will beat red is when red has a 4 (with probability 5/6) and green has a 5 (also with probability 5/6). So we have a probability of green beating red of 5/6 x 5/6 = 25/36. And the probability of winning as red (since again no draws are possible as the two dice have no numbers in common) is therefore 1 – 25/36 = 11/36. So, in the long run (when as Keynes once helpfully pointed out, we are all dead) green beats red, again exactly the opposite of what we would expect just going on the expected values.

We only had to mess around a little with the 6 faces of the dice to get this counter-intuitive result. Nearly all financial instruments and products are obviously much more complicated than this, with the probabilities of certain outcomes being largely unknown, and even more so when in combination with each other, and therefore counter-intuitive results turn up almost too frequently to be called counter-intuitive any more. In fact the habit of trying to treat financial markets as if they were games obeying rules as fixed and obvious as those you can play with dice is what Nassim Nicholas Taleb refers to as the Ludic Fallacy.

If we double them up we get another surprise. Red still has the highest expected value (8⅔), followed by green again (8⅓) and then blue (8). But this time each pairing has three possible outcomes. Red and green both beat blue as expected from the expected values, but then green unexpectedly beats red.

This kind of behaviour is called nonlinearity, when adding quantities of things together does not just increase their effects, but instead changes them. Nonlinearity in this case means that blue beats green when we use one die each, but that green beats blue when we use two. Nonlinearity is also the single biggest threat to the financial system.

Anyone for darts instead?

mobile pics Nov 2013 010Now that the Great and Good of the actuarial profession and pensions industry have launched their joint consultation with the DWP on defined ambition (DA) options, it is interesting to look at the initial response in the print media.

The first thing to note is how little of it there is. The Daily Mail, Daily Express and Daily Telegraph have it on the front page. The Financial Times, Guardian and Times do not. Nor do the red tops. All three headlines sit alongside photographs of the Duchess of Cambridge.

And the response varies. The Express have written what looks like a positive piece (“Bigger Better Pensions For All”) until you discover it has decided to present the launch of the consultation as an “industry shake-up” which will “spell the end of annuities”. I was a little puzzled about this at first, as the consultation is not really about annuities at all, until I realised that Steve Webb had made a speech the previous day and mentioned the FCA review of annuities. This clearly fed into the default Express editorial line better than the actual topic of the consultation. This became clearer on page 4, with the headline “’Poor value’ annuity payouts are axed in pensions shake-up” next to a big picture of a smiling Ros Altmann. There appears to be only one story possible in the Express on pensions, whatever the actual news event.

The Mail does at least focus on things that are in the consultation, concentrating on the proposals to allow final salary pensions to drop some currently guaranteed elements of benefits such as indexation and spouses’ pensions. “The Death Knell for Widows’ Pensions” is their headline, but the article beneath is fairly balanced on flexible defined benefit (DB), quoting both those highlighting the reductions to benefits the proposal would allow on the one hand, and the danger that all the remaining horses would bolt from the DB stable if changes were not made on the other.

Finally, the Telegraph. “Pensions face new blow from ministers” is their headline. The article is similarly balanced, and is the only one to make the important point that benefits already accrued would be unaffected.

The coverage of the alternatives put up for consultation is patchy. Strangely the Express does best here, despite its desperation to make it a story about the death of the annuity, it does mention in passing collective defined contribution (DC) and guaranteed DC. Otherwise the focus is exclusively on flexible DB in both the Mail and Telegraph, and what members currently accruing non-flexible DB might lose as a result. The comparison with public sector pensions is made several times, with the Telegraph pointing out that the recent settlement on public sector pensions, which would not be removing the requirement to provide indexation and spouses’ pensions, was promised by ministers to be the last for 25 years.

So what kind of start does this represent for engaging the UK public in the debate on the future on pension provision? Mixed, I think. There will clearly be much more scrutiny on any legislative easing to current benefit guarantees than there will be to any addition of guarantees on pensions which currently have none. Perhaps this is to be expected. I do worry that cash balance may get squashed out as an option between the two camps of flexible DB and guaranteed DC – it is barely mentioned in the consultation, and can work well when coupled with a strong commitment to employee education like Morrisons have attempted.

But these are early days and the first thing everybody needs to do is respond to the consultation. Most pensions actuaries and many others will have strong views on many elements of it. So don’t leave it to your firm to do it on your behalf. The deadline is 19 December.

This was a letter sent to The Actuary on 12 September, but which they chose to publish neither in the magazine nor on the website.

Dear Sir

In response to the interview with Philip Booth in the September issue, I would just like to point out that the banks did not know during the 2007 financial crisis that they would be bailed out. The day before Alistair Darling announced a £500 billion rescue package in October 2008, shares in RBS fell by almost 40 per cent to a 15-year low, HBOS fell by over 40 per cent, Lloyds TSB dropped by 13 per cent and Barclays by 9 per cent precisely because a bailout was not assumed.

As regards how prudently financial institutions behaved before the changes in insurance regulation in the 1970s and 1980s, I would prefer to listen to the views of someone who was actually there. Frank Redington, in his submission to the Institute of Actuaries in 1981 entitled The Flock and the Sheep and Other Essays, says:

“We have no means now of telling how the profession would have emerged from what would have been the only real test of its collective character which it has had to endure in the last 100 years. When the curtain fell in 1939 the profession was not cutting a very brave figure. Valuation bases were too weak, the rate of bonus was some £5 too high and new business was being sold on prospects which were not achieved until 18 years later. A few reputable offices had their backs to the wall.

“The outcome, if the war had not interrupted the story, would probably have taught us a valuable lesson. As it is we have to conclude regretfully that the profession had not – and, I am sure, has not – learned how to live with its salemen’s promises. To put it another way, we are driving a powerful car but have not yet proved our ability to handle the brakes.”

Regulation was inevitable. The problem which remains is that financial institutions in many cases are too complicated in their current form to regulate effectively. As Robert Reich, former US Secretary of Labor, puts it when arguing for the need to split Wall Street banks, they are “too big to fail, too big to jail, too big to curtail”!

Yours faithfully
Nick Foster

scan0005

 

A man is sentenced to 7 years in prison for selling bomb detectors which had no hope of detecting bombs. The contrast with the fate of those who have continued to sell complex mathematical models to both large financial institutions and their regulators over 20 years, which have no hope of protecting them from massive losses at the precise point when they are required, is illuminating.

The devices made by Gary Bolton were simply boxes with handles and antennae. The “black boxes” used by banks and insurers to determine their worst loss in a 1 in 200 probability scenario (the Value at Risk or “VaR” approach) are instead filled with mathematical models primed with rather a lot of assumptions.

The prosecution said Gary Bolton sold his boxes for up to £10,000 each, claiming they could detect explosives. Towers Watson’s RiskAgility (the dominant model in the UK insurance market) by contrast is difficult to price, as it is “bespoke” for each client. However, according to Insurance ERM magazine in October 2011, for Igloo, their other financial modelling platform, “software solutions range from £50,000 to £500,000 but there is no upper limit as you can keep adding to your solution”.

Gary Bolton’s prosecutors claimed that “soldiers, police officers, customs officers and many others put their trust in a device which worked no better than random chance”. Similar things could be said about bankers during 2008 about a device which worked worse the further the financial variables being modelled strayed from the normal distribution.

As he passed sentence, Judge Richard Hone QC described the equipment as “useless” and “dross” and said Bolton had damaged the reputation of British trade abroad. By contrast, despite a brief consideration of alternatives to the VaR approach by the Basel Committee on Banking Supervision in 2012, it remains firmly in place as the statutory measure of solvency for both banks and insurers.

The court was told Bolton knew the devices – which were also alleged to be able to detect drugs, tobacco, ivory and cash – did not work, but continued to supply them to be sold to overseas businesses. In Value at Risk: Any Lessons from the Crash of Long-Term Capital Management (LTCM)? Mete Feridun of Loughborough University in Spring 2005 set out to analyse the failure of the Long Term Capital Management (LTCM) hedge fund in 1998 from a risk management perspective, aiming at deriving implications for the managers of financial institutions and for the regulating authorities. This study concluded that the LTCM’s failure could be attributed primarily to its VaR system, which failed to estimate the fund’s potential risk exposure correctly. Many other studies agreed.

“You were determined to bolster the illusion that the devices worked and you knew there was a spurious science to produce that end,” Judge Hone said to Bolton. This brings to mind the actions of Philippe Jorion, Professor of Finance at the Graduate School of Management at the University of California at Irvine, who, by the winter of 2009 was already proclaiming that “VaR itself was not the culprit, however. Rather it was the way this risk management tool was employed.” He also helpfully pointed out that LTCM were very profitable in 2005 and 2006. He and others have been muddying the waters ever since.

“They had a random detection rate. They were useless.” concluded Judge Hone. Whereas VaR had a protective effect only within what were regarded as “possible” market environments, ie something similar to what had been seen before during relatively calm market conditions. In fact, VaR became less helpful the more people adopted it, as everyone using it ended up with similar trading positions, which they then attempted to exit at the same time. This meant that buyers could not be found when they were needed and the positions of the hapless VaR customers tanked even further.

Gary Bolton’s jurors concluded that, if you sell people a box that tells them they are safe when they are not, it is morally reprehensible. I think I agree with them.

I think if I were to ask you what you thought the best way to manage risk was, there would be a significant risk that you would give me a very boring answer. I imagine it would involve complicated mathematical valuation systems, stochastic models and spreadsheets, lots of spreadsheets, risk indicators, traffic light arrangements, risk registers. If you work for an insurance company, particularly on the actuarial side, it would be very quantified, with calculations of the reserves required to meet “1 in 200 year” risks featuring heavily. Recently even operational risk is increasingly being approached from a more quantifiable angle, with Big Data being collected across many users to pool and estimate risk probabilities.

Now you can argue about these approaches, and particularly about the Value at Risk (VaR) tool which has brought this 1 in 200 probability over the next year into nearly every risk calculation carried out in the financial sector, and the Gaussian copula which allows you to take advantage of a correlation matrix to take credit for the “fact” that combinations of very bad things happening are vanishingly rare (the “Gaussian” referring to the normal distribution that makes events more than three standard deviations or “sigma” away from the average vanishingly rare), rather than actually quite likely once the market environment gets bleak enough. The losses at Fortis and AIG 2008 were over 5 and 16 sigma above their averages respectively.

The news last week that the US Attorney for the Southern District of New York had charged two JP Morgan traders with fraud in connection with the recent $6.2 billion “London whale” trading losses reminded me that VaR as it is currently used was largely cooked up at JP Morgan in the early 90s. VaR is now inescapable in the financial industry, having now effectively been baked into both the Basel 2 regulatory structure for banks and Solvency 2 for insurers.

The common approaches to so-called “quantifiable” risk may have their critics, but at least they are being widely discussed (the famous debate from 1997 between Phillippe Jorion and Nassim Nicholas Taleb just one such discussion). However, one of the other big problems with risk management is that we rarely get off the above “boring” topics, and people who don’t get the maths often think therefore that risk management is difficult to understand. In my view we should be talking much more about what companies are famous for (because this is also where their vulnerability lies) and the small number of key people they totally rely on (not all of whom they may even be aware of).

If you asked most financial firms what they were famous for, I imagine that having a good reputation as a company that can be trusted with your money would score pretty highly.

A recent survey of the impact of the loss of reputation amongst financial services companies on Wall Street revealed that 44% of them lost 5% or more in business in the past 12 months due to ongoing reputation and customer satisfaction issues. Losses based on total sales of these companies are estimated at hundreds of millions of dollars. There was an average loss of 9% of business among all companies surveyed.

And the key people we totally rely on? Well, just looking at the top five rogue traders (before the London Whale), we have:

1. SocGen losing 4.9 billion Euros in 2008 when Jerome Kerviel was found guilty of breach of trust, forgery and unauthorized use of the bank’s computers in their Paris office with respect to European Stock Index futures.
2. Sumitomo Corp losing $2.6 billion in 1996 when Yasuo Hamanaka made unauthorised trades while controlling 5% of the world’s copper market from Tokyo.
3. UBS losing $2.3 billion in 2011 when Kweku Adoboli was found guilty of abusing his position as an equity trade support analyst in London with unauthorised futures trading.
4. Barings Bank losing $1.3 billion in 1995 when Nick Leeson made unauthorised speculative trades (specifically in Nikkei Index futures) as a derivatives broker also in London.
5. Resona Holdings losing $1.1 billion in 1995 when Toshihide Iguchi made 30,000 unauthorized trades over a period of 11 years beginning in 1984 in US Treasury bonds in Osaka and New York.

None of these traders will, of course, have done anything for the reputations of their respective organisations either.

These are risks that can’t be managed by just throwing money at them or constructing complicated mathematical models. Managing them effectively requires intimate knowledge of your customers and what is most important in your relationship with them, who your key people are (not necessarily the most senior, Jerome Kerviel was only a junior trader at his bank) and what they are up to on a daily basis, ie what has always been understood as good business management.

And that doesn’t involve any boring mathematics at all.