The use of pension protection schemes (PPS) within calculations for the holistic balance sheet (HBS) has caused disagreements among Europe’s pension funds.
A consultation from the European Insurance and Occupational Pensions Authority (EIOPA) on the HBS closed last week, with respondents generally rejecting the idea.
However, in its consultation, EIOPA raised the debate over whether pension protection schemes should form part of the balancing items for potential solvency capital requirements – minimum funding levels of risk management tools in four of the proposed six models.
The UK’s Pension Protection Fund (PPF) said, in principle, a PPS could be considered as impacting on sponsor support and thus used as a balancing item for the HBS.
However, it said, in its case, it should not be used if the HBS is used for solvency or funding purposes.
“[The PPF] steps in to compensate members when their pension schemes have insufficient funds to pay the pensions promised following a sponsor’s insolvency,” the fund said.
“The trustees should not be running the scheme finances taking into account any compensation payable following the scheme’s disappearance, and to include the PPF on the balance sheet would run the risk trustees and employers came to target PPF levels of compensation.”
The scheme also said that, where a PPS was used as a balancing item, a separate minimum level of funding with financial assets or sponsor support should be required.
“We would be concerned the incentive for trustees and sponsors to properly fund their pension scheme would be reduced if there were no minimum funding requirement and the scheme’s HBS always balanced,” it added.
However, the German pension fund association (aba) and the UK’s National Association of Pension Funds (NAPF) disagreed with the PPF over additional minimum-funding requirements.
The aba said a PPS should be included as a balancing item, as it could be seen as collective sponsor support.
“In the case of a strong sponsor or a sponsor backed by a pension protection scheme, the pension promise is safeguarded,” it said.
“That is the rationale for treating these security mechanisms as balancing items. Thus, an additional separate minimum level of funding with financial assets should not be required.”
Aon Hewitt, which took views from consultants across its European offices, said it was unconvinced a PPS should be used as a balancing item at all, unless it covered 100% of benefits.
“To do so would create the possibility pension schemes would be under-funded in the event of employer insolvency, and this would then put pressure on the financing of the pension protection scheme itself,” Aon Hewitt said.
Towers Watson’s UK office responded by siding with the PPF, but added that it should not come within EIOPA’s remit.
“The protection of the PPS will require a separate minimum funding level based on financial assets/sponsor support to protect the viability of the PPS,” it said.
“However, this is something that is best determined by the relevant individual member state and its national competent authority.”
Consultation respondents also criticised EIOPA over conflicting views in its consultation and called for delays until all key factors were decided by the Authority.