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ITEM PF16
PENSION
FUND COMMITTEE – 21 MAY 2004
THE FUNDING
STRATEGY STATEMENT
Report by
Head of Finance
Introduction
- This Committee
received a report at its August 2003 meeting on proposals from the Office
of the Deputy Prime Minister (ODPM) to require the development of a
Funding Strategy Statement. The ODPM has now published regulations to
enact this requirement, and the first Funding Strategy Statement must
be published by 31 March 2005. CIPFA’s Pension Panel have published
guidance on preparing and maintaining the statement, and administering
authorities must have regard to this guidance in compiling their Statement.
- This report sets
out the key requirements of the regulations and associated guidance,
highlights some of the key issues that will need to be addressed before
the Statement can be finalised, and proposes a process and timetable
that will enable this Committee to meet its obligations.
The Content
of the Funding Strategy Statement
- The content of
the statement is set out within the CIPFA guidance. There is a requirement
to include sections on:
- the purpose
of the Funding Strategy Statement,
- the aims and
purpose of the Pension Fund,
- the responsibilities
of key parties,
- solvency issues
and target funding levels,
- links to the
investment policy, and
- the identification
of risks and appropriate counter measures.
- The ODPM’s stated
purpose behind the Funding Strategy Statement is to provide a clear
statement of how the Administering Authority is going to meet the Pension
Fund’s liabilities in the future. The increase in transparency and accountability
should benefit all employers and scheme members, and should help in
gaining greater understanding of the links to Council tax increases.
- The ODPM also
sees the introduction of the Statement as providing a framework under
which Administering Authorities can take a prudent but longer term view
of funding future liabilities. This in turn should allow Administering
Authorities to plan for a more stable employers’ contribution rate,
in line with the regulatory requirements.
- The ODPM and the
CIPFA guidance make it clear that there should be appropriate consultations
in preparing the Statement. The CIPFA guidance defines this as meaningful
dialogue with officers and elected members of all tax raising employing
authorities, and with corresponding representatives of the other employing
organisations. The guidance is clear that this dialogue should start
at the initial preparation of the statement, and continue throughout
the process.
- Whilst the final
Funding Strategy Statement is not required to be published before 31
March 2005, the regulations and guidance make it clear that the Actuary
must have regard to the Statement in completing the 2004 Fund valuation.
The Statement must therefore exist in draft form later this year, to
influence the discussions with the Actuary in respect of the Valuation
results.
Issues
Associated with the Funding Strategy Statement
- The main issues
to be associated with the development of the Funding Strategy Statement
are likely to be around the degree different employers wish to follow
their own strategies. The main areas of contention could be around the
period set to recover any funding deficit, and around investment patterns.
The development of the Statement will require all employers to consider
these issues in much greater detail than they have previously.
- Traditionally,
the Actuary has determined the period over which any Fund deficit is
to be recovered, as part of the Valuation process. A single recovery
period has been set for the Fund as a whole. The period has traditionally
been around 12 to 13 years, reflecting the average future working life
of Fund members.
- Part of the reasoning
for the introduction of the Funding Strategy Statement is to encourage
a more prudent longer term view of the recovery period for any Fund
deficit. Actuaries are therefore likely to be discussing recovery periods
of 20 to 30 years for the current valuation.
- Different employers
are likely to have a different view as to the extent that the recovery
period is extended. Risk adverse and cash rich employers will be looking
for the shortest possible recovery period. Employers with a high appetite
for risk, and a limited ability to raise additional income will be looking
for the longest possible recovery period.
- There will also
be the need to take a view on the membership profile of each employer.
Those employers with an aging or declining number of scheme members
will have a limited ability to extend the current recovery period, whereas
those with growing membership can spread recovery over a longer period.
- The extent to
which the Funding Strategy Statement can accommodate each individual
employer’s wishes, and the extent to which we can continue to group
the small employers for contribution rate purposes, will be one of the
future challenges.
- The second challenge
will be around the extent that employers are seeking different investment
patterns. The Funding Strategy Statement must show how the investment
strategy is compatible with the funding strategy, and cover the risks
associated with the different strategies.
- Risk adverse employers,
and those with mature scheme membership, will be looking for safer investment
returns, associated with assets such as index-linked bonds. However,
when linked to a short recovery period, this will require sharp increases
in employer contribution rates.
- Employers with
a greater appetite for risk, and growing scheme membership may well
be happier with a riskier investment strategy, based predominantly on
equities.
- In finalising
the Funding Strategy Statement, this Committee will need to consider
the various wishes from the employers, and determine to what extent
these can be met, and the administration costs of running separate investment
strategies for different employers.
Proposed
Timetable
- The proposed timetable
for meeting the above requirements is as follows:
- July 2004: Workshop
with all employers invited at officer and member (or equivalent) level,
to provide an outline of the requirements associated with the Funding
Strategy Statement, and the key consultation issues that each employer
needs to consider. The workshop would be a joint venture between officers
from the administering authority and the Fund Actuary. Detailed information
packs covering the regulations, the CIPFA guidance and the draft Statement
will be available following the workshop.
- September 2004:
Individual sessions between officers of the administering authority
and each employer to discuss the key issues from the perspective of
each employer, and to allow employers to clarify outstanding issues.
- October 2004:
Close of initial consultation process.
- November 2004:
Presentation of draft Funding Strategy Statement to the Pension Fund
Committee
- December 2004/January
2005: Refinement of draft Statement in discussion with the Actuary
in the light of the results of the Valuation process. Further discussion
with employers.
- February 2005:
Final Funding Strategy Statement and 2004 Valuation Results reported
to Pension Fund Committee.
- March 2005:
Publish Funding Strategy Statement.
RECOMMENDATION
- The Committee
is RECOMMENDED to note the report, endorse the timetable set out in
paragraph 18, and determine what other involvement, if any, it wishes
to have in the process.
CHRIS
GRAY
Head of Finance
Background Papers: The Local Government Pension Scheme (England and
Wales) (Amendment) Regulations 2004 - ODPM
Guidance
on Preparing and Maintaining a Funding Strategy Statement - CIPFA
Contact
Officer: Sean Collins, Assistant Head of Finance Tel: (01865) 815411
May
2004
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