The pension funds of FTSE 350 companies are carrying £100bn (€140bn) in investment risk underwritten by their sponsors as they struggle to adapt to the regulator’s new holistic risk approach.

Advisory firm Lincoln Pensions said it saw little evidence FTSE 350 schemes were implementing The Pensions Regulator’s (TPR) holistic risk-management approach.

This approach, published in the DB Code of Funding last July, calls on schemes to account for the strength of the employer covenant when calculating investment-risk tolerance and thereby ensure risks between a company and its pension fund are balanced. 

The regulator said pension funds’ approach to funding and deficits should take into account all risks and that they should find appropriate investment-risk tolerances in line with risks stemming from sponsor failure.

Lincoln Pensions suggested that the publication of separate TPR guidance, detailing how pension funds might support the growth of their sponsors, could be responsible for the lack of holistic-risk implementation at FTSE 350 companies. 

According to research conducted by the firm, pension funds supporting the growth of their sponsor companies are forced to increase investment risk to offset lower contributions and a weaker covenant. 

The research also found that FTSE 350 schemes that depend more on their employers, as opposed to their covenants, also tend to have higher allocations to risk-seeking assets.

“[This indicates] schemes may be trying to invest their way to full funding,” Lincoln’s research says.

“In doing this, they may be taking too much investment risk relative to the employer covenant rather than seeking increased contributions from their employers.”

Lincoln also found that FTSE 350 schemes had an accounting deficit of £72bn, but this is combined with the £100bn of investment risk – with the average allocation to risk assets at 44%.

Matthew Harrison, managing director at Lincoln Pensions, said: “The share of return-seeking assets does not decrease as the schemes get larger in the context of their employer, despite clear guidelines in TPR’s code of practice on funding [schemes].

“[The] analysis may lead to scheme funding discussions that move away from the historical focus on funding today’s deficit towards a greater understanding of investment risk volatility and a balance in the scheme’s overall risk profile.”