Independent Report supports Colm Fagan's alternative AE proposal

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Duke of Marmalade

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Minutes of the PC meeting in September are at last available. This is the key minute.

Edit: I have brought his conclusion to the top: (The CF is Colm Fitzgerald the independent expert and not Colm Fagan the proposer.)


Advantages of the Alternative AE Proposal: CF stated that in its current form, the Alternative AE Proposal could produce significantly higher pensions for those contributing to it. CF listed some other advantages that he believed the Alternative AE proposal would deliver:
• Adopting the proposal could improve Ireland’s credit rating in the long-term.
• Higher projected pensions would increase future income tax revenue from retirees and improve social protection
• If it were a success, it could become more attractive and encourage higher levels of opting in, resulting in higher future pensions coverage.
• It would effectively lower the cost of providing pensions in the State.

Analysis: CF carried out a set of projections for a worker joining AE at ages between 25 and 55, earning €20,000 per annum, based on a set of assumptions . The results showed that the member would be significantly better off under the Alternative AE Proposal, reflecting the significantly higher investment return being assumed under that approach.

4. Presentation – Review of Alternative proposal for auto enrolment (AE)
The Chair stated that the purpose of this meeting was for the Council members to listen to a presentation by Dr. Colm Fitzgerald, who through his company Paragon Research Limited, was awarded the contract for the project to analyse and assess the model proposed in the paper ‘Alternative proposal for auto enrolment (AE)’ which was furnished to the Department of Social Protection by Mr. Colm Fagan.The Chair stated that this project was multi-faceted and a very complex topic. She thanked the Technical Oversight Committee for its work supporting Dr. Fitzgerald during his assessment. Dr. Colm Fitzgerald (CF) summarised his professional and academic background as an actuary, investor, company owner, and university lecturer, and pointed out that his approach to conducting the assessment of the project was to ‘get the story right’ and look at the proposal more from an investor’s perspective, taking a multidisciplinary approach, rather than purely from the perspective of an actuary.

CF presented his draft findings. He stated that he had conducted an independent multi-disciplinary real-world assessment and made every effort do this objectively. To assist with this, he had consulted experts from a wide variety of fields who had differing views on the subject matter, all of whom were referenced in his slides and some of whom were suggested by Colm Fagan.

Background: CF referenced an observed increase in longevity and a shift away from employers providing defined benefit pensions. Longevity risk is being passed from organisations to individuals. CF referenced Alexis de Tocqueville’s concept of equality, developed through his work analysing living standards and social conditions. CF spoke about the need for social protection; in this regard, that interests are aligned at individual and State level.

CF spoke about investing in the stock market and the risks involved. CF stated that when investing, it is important that investors have the psychological capacity not to panic when markets fall and that they remain invested. Under the Alternative AE Proposal, all members would be invested 100% in equities, the risk is passed to the members, but this is managed with a smoothing formula at which members would transact with each other.

CF stated the need for prudential investment oversight by a competent person of appropriate character and investment expertise. CF quoted economist and investor Benjamin Graham: “Successful investing is about managing risk, not avoiding it.”

Technical feasibility testing: CF summarised the way in which the Alternative AE Proposal works and discussed the key features, drivers, risks, analysis, assumptions, and potential advantages.

Key features:
• Investment in a single fund investing 100% in equities during pre- and postretirement phases, with a formula to smooth how returns are allocated to member accounts.
• Members remain in the fund for life, with an alternative approach to provide longevity protection.

Key drivers:•
The main driver over longer periods is the market value.
• The ‘i’ in the formula is the artificial increase in smoothed value that is intended to reflect the long-term expected return on equity.
• The ‘p’ in the formula is the rate at which the recognition of changes in market value is delayed.

Key risks: CF stated that the key risks present in the Alternative AE Proposal are:
• Political and governance risk (and not managing expectations properly).
• Scheme becoming unattractive and contributions stopping.
• Investment risk (the average return on equities changing versus history).
• Funding level risk.
• Lack of sound risk management.
• Risk to the State’s finances (existing risk from other obligations and population risk).
• Social protection risk
• Inflation risk.
• Expense risk
• IT risk
• Modelling risk
• Investment psychology risk and behavioural risk.
• Lack of oversight by a competent person of appropriate character and investment expertise.


Data used for assumptions:
In order for CF to test the technical feasibility of the Alternative AE Proposal, he looked at the past performance over extended periods of time (which included events such as social unrest, two world wars and the Spanish Flu) of the economies of the United States (from 1871 to 2010) and Belgium (from 1833 to 2005).

He noted that in some cases the market value was in excess of or below the smoothed value in both scenarios. CF discussed how equities performed under different scenarios and concluded that, counterintuitively, equities, though more volatile in the short-term, performed better than bonds during periods where high inflation served to reduce bond valuations to nil – such as in times of a pandemic and more generally during challenging times, be that political, economic or social.

Analysis: CF carried out a set of projections for a worker joining AE at ages between 25 and 55, earning €20,000 per annum, based on a set of assumptions . The results showed that the member would be significantly better off under the Alternative AE Proposal, reflecting the significantly higher investment return being assumed under that approach.

Assumptions:
CF discussed the key assumptions: i and p, the Buffer Account and the assumption regarding no political interference. The i and p was discussed as outlined earlier. In CF’s view, the assumption regarding the Buffer Account was not credible. In the event that the fund had to wind-up, depending on market value at that time, the Buffer Account might not be sufficient to pay out every member’s benefits, in which case the State might have to provide the necessary financial resources. CF described the overall risk as analogous to the risks associated with the introduction of the Euro.

For the Alternative AE Proposal to be a success, four risk management approaches were set out: the State could stand behind it, or this risk would need to be hedged in the market, or a person of appropriate character would need to be appointed to manage the fund with a more simplistic approach to smoothing being applied; or a combination of the options. CF stated that the assumption made in the Alternative AE Proposal regarding no political interference was not credible, but that, like with the Euro and with other examples, measures could be taken to reasonably protect against it.

Advantages of the Alternative AE Proposal: CF stated that in its current form, the Alternative AE Proposal could produce significantly higher pensions for those contributing to it. CF listed some other advantages that he believed the Alternative AE proposal would deliver:
• Adopting the proposal could improve Ireland’s credit rating in the long-term.
• Higher projected pensions would increase future income tax revenue from retirees and improve social protection
• If it were a success, it could become more attractive and encourage higher levels of opting in, resulting in higher future pensions coverage.
• It would effectively lower the cost of providing pensions in the State.

Caveats: CF stated that he did not consider the post-retirement phase during the presentation, due to time constraints, but that this would be referenced in the final report.

Queries from the Council: An extensive and broad ranging discussion ensued. The Council members posed many questions, among those were:
• To what extent can we rely on past data for the future?
• The stock market cannot grow at a faster rate than the economy indefinitely –how is this being considered?
• To what extent can an assumption be made that it would be the State’s number one priority to bail out a pension fund in times of crisis? And should society bear those risks?
• Is there capacity in the market for everyone to do this?
• On what basis can we assume that this is a reliable equity basis?
• How was investment in index-linked bonds captured in CF analysis, in circumstances where high inflation caused bond values to fall significantly? (CF stated that he will revert to the Council on this.)
• What evidence do we have to satisfy ourselves that all associated risks can be managed?
• How has intergenerational fairness been taken into account?

The Chair thanked CF for his presentation and noted the remit of the Pensions Council which is to provide advice to the Minister on matters relating to pension policy and to represent and protect the consumer interest and to ensure that the pension system has a stronger consumer focus.

Next steps: It was agreed that CF would submit his draft assessment report to the Council before the end of October 2023.The Council members agreed to meet during the following week to continue the discussion. The Secretariat would share CF’s presentation slides with all Council members.
 
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Hi @nest egg Sorry, I can't help you, as I haven't seen the report myself. All I've seen is the minute on the Pension Council's website, quoted above.
 
Independent evaluation of Colm's proposal said:
CF carried out a set of projections for a worker joining AE at ages between 25 and 55, earning €20,000 per annum, based on a set of assumptions . The results showed that the member would be significantly better off under the Alternative AE Proposal, reflecting the significantly higher investment return being assumed under that approach.
CF described the overall risk as analogous to the risks associated with the introduction of the Euro.
Game, set and match for Colm's proposal.
 
Hi @nest egg Sorry, I can't help you, as I haven't seen the report myself. All I've seen is the minute on the Pension Council's website, quoted above.
Níl fhios agam. Seems incredible that they would have commissioned an independent evaluation of your proposal, and plan to publish their own report on the evaluator’s assessment without seeking your input (or even sharing the report).
 
I agree that it seems strange not to share with me either Colm Fitzgerald's evaluation of my alternative approach to AE, nor Pension Council's report on the evaluation, but I'm sure that there are good reasons for the decision. For the record, Brian Woods and I offered to share all our workings, spreadsheets and analyses (much of which can be found on my website colmfagan.ie) on a pro bono basis, but Colm Fitz and the Pensions Council preferred not to take up our offer.
Given its importance for the country's future (I'm claiming that my proposal saves €1.5 billion a year in contributions from employers, workers and the state when the scheme is mature) it is vital that my proposal AND Colm's evaluation AND the Pension Council's report be discussed in a public forum, open to all. Such a discussion is now inevitable. It's just a question of time. Let's hope it happens sooner rather than later.
 
Well done!

That is some endorsement. It couldn't have been any stronger had you written it yourself.
Thanks Brendan. You're right! I couldn't reasonably have hoped for an unqualified endorsement, especially when I wasn't able to correct the inevitable misunderstandings. I'm hoping that the debate still has a long way to go and that there will be plenty of opportunities to set the record straight. I'm looking forward to that discussion.
 
Pensions Council query said:
The stock market cannot grow at a faster rate than the economy indefinitely –how is this being considered?
Rather basic misunderstanding. Colm's proposal makes no such assumption. In a stationary state one would expect investments in the stockmarket to mirror growth in the economy. Pensions should also mirror growth in the economy. Yes, if this means the economy weakens pensioners' wellbeing will weaken along with that of active workers. If you want to enjoy the fruits of the economy you must bear the risks of the economy.
So real assets are the natural fit for pensions. In fact everybody agrees that for most of the accumulation period pension funds should be almost entirely invested in real assets. Has the PC considered what happens in this accumulation phase if the stockmarket does not grow faster than the economy?
But the big problem which Colm's proposal claims to address is the individual timing risk. The conventional approach is to minimise this by "lifestyling" but that involves paying a very high "insurance" price, forgoing the Equity Risk Premium. Colm modelled his proposal on an ERP assumption of 4% p.a. and that is what causes the DSP proposal to double the more natural economy based cost of pensions.
Unfortunately if the person has naked exposure to individualised timing risk, lifestyling may be a necessary evil.
And that is the whole point of Colm's proposal. It pools the timing risk.
 
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Forgive my ignorance, but aren’t stock market growth and returns a function of dividends (i.e. the fruit of past economic activity) plus the growth in those dividends (i.e. economic growth, crudely speaking)?
 
So what was that person’s point about stock markets not keeping up with economic growth?
Exactly, what was the point? To be charitable, I suppose much of the "back testing" was against markets that did outperform their economies and so it is a version of the past is not a guide to the future.
The less charitable interpretation is that there are those on PC ideologically opposed to Colm's proposal and they have misrepresented it.
 
Considering

1. The Pensions Council didn't want Colm Fagan's proposal to be evaluated by an independent expert in the first place and only did so after being bypassed and the Minister's subsequent insistance;
2. The delay in publishing minutes showing the independent expert's analysis agreeing with Colm Fagan's proposal;
3. Failure to publish the independent expert's report;
4. The Pension Council opting to write their own report for the Minister on their interpretation of the evaluation

It seems to me, more likely than not, the Pensions Council already had a pre-determined outcome in mind - not to adopt Colm Fagan's proposal. This will have been their conclusion in their report to the Minister - who at this stage has likely already received their report but this is private.

I wouldn't be surprised if they also omitted to send the Minister a copy of the independent expert's report so as not to show it contradicts their own report.
 
Considering

1. The Pensions Council didn't want Colm Fagan's proposal to be evaluated by an independent expert in the first place and only did so after being bypassed and the Minister's subsequent insistance;
2. The delay in publishing minutes showing the independent expert's analysis agreeing with Colm Fagan's proposal;
3. Failure to publish the independent expert's report;
4. The Pension Council opting to write their own report for the Minister on their interpretation of the evaluation

It seems to me, more likely than not, the Pensions Council already had a pre-determined outcome in mind - not to adopt Colm Fagan's proposal. This will have been their conclusion in their report to the Minister - who at this stage has likely already received their report but this is private.

I wouldn't be surprised if they also omitted to send the Minister a copy of the independent expert's report so as not to show it contradicts their own report.
This debate has been going on for 5 years. We know from the minutes that the majority of the PC are opposed. An evaluation by a single actuary, reluctantly commissioned by the PC in response to the Minister's request, is not going to change any of their minds, as evidenced by some of the issues raised by the PC in response to the report. The issue is bigger than the PC and should be subject to something like an "Experts' Assembly", including leading economists, which I understand are conspicuously lacking in the PC.
 
Let me try to put myself in their shoes. I suspect the PC (and DSP) are hesitant to recommend a novel approach for something like AE which will have such a broad impact. In addition, given the poor uptake in private pensions today, presumably 'any scheme is better than no scheme' is the prevailing mantra. Openly speaking, this isn't an unreasonable position to take.

I work for a large MNC and 'tried and tested' is often preferred to 'new and unknown'. However the best outcomes typically come from decisions taken after scrutinising several options.

We know that the smoothed approach has been subject to an independent evaluation. In the interest of fairness, has the proposed AE scheme had a similar independent evaluation?
 
We know that the smoothed approach has been subject to an independent evaluation. In the interest of fairness, has the proposed AE scheme had a similar independent evaluation?
Good question, @nest egg The quick answer is that, to the best of my knowledge, the scheme proposed by DSP has not been independently evaluated. It is vital to have one.
To illustrate why, when trying to compare my proposal for post-retirement charges with what customers would be charged under the DSP's plan, I had to estimate what ARF holder are being charged at present.
I got my hands on an ARF 'product guide' from one of Ireland's leading life companies. Written in bold at the top was: "This is not a customer document and is intended for Financial Brokers and Advisers only." It's obvious why it's not a customer document. It shows different customer terms depending on the commission option chosen by the broker/ adviser.
In short, the adviser can choose initial commission of between 0% and 5% and trail (recurring forever) commission of between 0% and 0.5% a year of AUM. You don't have to be a genius to see how customer terms differ depending on the adviser's commission choice.
The insurer in question doesn't have any criteria for deciding what trail commission the broker gets, so one customer could be charged 0.5% a year more than another, with no difference in service levels. In fact, the customer being charged more could get a poorer service. As an aside, I wonder if the insurer's Directors are happy with this? I doubt if I would be if I were on the Board.
In order to do the comparison, I had to estimate the average trail commission for customers. I didn't have the authority to ask the companies concerned. I wonder if the Pensions Council has ever asked that question of insurers? I wonder if Dr Colm Fitzgerald asked it as part of his evaluation of my proposal versus the scheme as proposed by DSP?
To see what I did assume, I refer you to (ii) and (iii) on p26/27 of my paper for the UK actuaries' competition here. I would appreciate if someone on this forum, more well-versed in such matters, could advise if I overestimated or underestimated the charges.
BTW, I'd say the average charge for the insurer's overall portfolio is much lower than the average charge for lower-income, less sophisticated customers, who are the primary target market for AE, since they will mainly be customers of lower-quality brokers/ advisers.
This is the sort of issue the PC should be pursuing.
 
Attached is a report on ARF charges from 2016 by...the Pensions Council. Of interest is the median ARF charges and the spread around them as shown below.
1703160642559.png
 

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  • report-on-arf-charges.pdf
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@Duke of Marmalade
Thanks. That seems the sort of analysis I’m looking for, but from a brief perusal it raises more questions than answers. I’ll get back to you when I’ve studied it.
 
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