Relax Luther, it’s much worse than you think

24. April 2013 · Write a comment · Categories: Actuarial, EIOPA

On 9 April, the European Insurance and Occupational Pensions Authority (EIOPA) published the preliminary findings of the quantitative impact study on its proposed changes to the Institutions for Occupational Retirement Provision Directive (or IORP II as some have started to call it). That sentence might not mean much to many people. But once you understand that EIOPA is the pensions regulator for the whole EU and that IORP is the European word for pension scheme you will probably be expecting bad news. And you would be right.

The study showed that the combined deficits of the 6,432 defined benefit pension schemes in the UK as at 31 December 2011 would have increased from £300bn (the UK Pensions Regulator’s calculated figure) to £450bn (based on methodology designed to bring pension funding more in line with insurance company reserving).

The National Association of Pension Funds warned that this move would put a “huge burden” on remaining UK defined benefit pension schemes and the businesses that run them.  Steve Webb warned that “The EU’s latest figures show the extremely high cost its plans would place on UK defined benefit pension schemes.”

Others were less positive about the proposed changes.

However, I am reminded every time this story is reanimated by the latest stage in the unending dance of death of the European insurance and pensions legislative process, of the line Tom Cruise uses in Mission Impossible to calm objections to his scheme to break into CIA Headquarters. It really is much worse than you think.

IORP II was set in motion with 3 main aims:

  • to make cross border schemes more widely used (which are avoided by most UK employers as they require an immediate increase in funding level in most cases);
  • to create a level playing field between pensions and insurance; and
  • to make sure that this level playing field includes a common supervisory system at EU level which is risk-based.

Which all adds up to a lot more than just a new funding requirement.

Therefore, quite apart from any proposals on extra funding, in over 500 pages of advice to the European Commission last year, EIOPA recommended:

  • The same governance requirements for pension schemes as for insurers. Getting governance and the documentation of it right has and continues to be a challenge for insurers with all of the resources available to them. Can trustees of pension schemes realistically be expected to do the same?
  • Fit and proper requirements for pension scheme trustees equivalent to the requirements of boards of insurance companies. The implication is that the current trustee toolkit might not cut it any more. Might this mean the end of the non-professional trustee?
  • Similar risk management requirements for pension schemes to those of insurers. This would include the possibility of pension schemes needing to set up contingency funds for “operational risks”, eg errors made in administering the scheme that might lead to losses, for the first time.
  • The requirement to conduct an Own Risk and Solvency Assessment (ORSA) for pension schemes. Again, these are very demanding exercises for insurance companies who have whole departments devoted to conducting them.

I could go on. Unfortunately the one thing that is certain is that EIOPA will go on. They have demonstrated through the tortuous nature of the process to date that their tolerance of bureaucracy is almost unlimited. There is a principle of proportionality referred to in the recommendations, which is supposed to mean that no organisation has requirements foisted on it totally out of proportion to the risks it poses to the financial system, but this has yet to be properly tested.

My fear therefore is that what we might have assumed would be regarded as unreasonable requirements of groups of mainly volunteer trustees trying to look after member benefits in their pension schemes will be viewed by the European institutions who will vote on these recommendations as nothing of the sort.

Actuaries and Science Fiction

18. April 2013 · Write a comment · Categories: Actuarial, Prediction, Science Fiction

Brian Aldiss told me a story the other week (at the Birmingham Science Fiction Group, where he is an honorary president) about Margaret Thatcher and her attitude towards science fiction. Kingsley Amis had been invited to a party at Downing Street and had decided to take along an inscribed copy of his latest book Russian Hide and Seek. Mrs Thatcher, a little suspicious about what she was being handed, had apparently asked what it was about.

Amis had explained that it was set in the future when the UK had been under Russian occupation for 50 years.

“Can’t you do any better than that?” the Prime Minister is reported to have said. “Get yourself another crystal ball.”

Aldiss recounted this story as he felt it illustrated how Mrs Thatcher totally misunderstood what science fiction was about. It was not about prediction of the future, but for people who “liked the disorientation” (the essence of science fiction in Aldiss’s view) of portraying an unfamiliar landscape and trying to work out what would hold true under different circumstances.

It seems to me that this is also what being an actuary is about. Actuaries are not about prediction either, but they are prepared to embrace the disorientation of asking what ifs and exploring maybes, and, by so doing, try to quantify what different currently unfamiliar landscapes might look like.

Science fiction has many forms but two main camps politically: the camp which believes a more enlightened form of society is possible (although what that means might vary considerably between different campers); and the camp which doesn’t but instead believes that all we can hope to do is survive a remorseless universe governed by nothing more than the laws of physics and evolutionary biology.

I think actuaries may have leaned more towards the second of these world views, particularly in fulfilling their statutory roles in recent years. We have worked within the remorseless universe of regulators and assumed that increasingly complex systems will make us safer in a Darwinian financial world. However the group think this has inevitably promoted has made us all less safe. As a result, we have heard many voices in the discussions about the financial crisis, including many what ifs and maybes, but few of these voices have been actuaries’. To quote Bob Godfrey (admittedly he was talking about animation at the time), the professionals are in a rut and the amateurs aren’t good enough.

Actuaries need to put themselves about as much as the amateurs do. Sometimes that will be uncomfortable. Sometimes we may look a little foolish for a while. But in my view it is the only way we are going to contribute meaningfully to the construction of a better society. And we might even produce some decent science fiction in the process.

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