The small but rich Dutch pension fund HAL indicated it considered the policy of supervisor De Nederlandsche Bank (DNB) as encouraging small schemes to liquidate and a risk to its existence.
In its annual report for 2016, the €132m scheme, with a nominal funding of 184%, said it had spotted a tendency at DNB to categorically perceive small pension funds as not futureproof.
The board of Pensioenfonds HAL, which was established by the shipping company Holland America Line, responded to a warning from its visitation committee for internal supervision, an external body, which had also spotted risks as a consequence of supervisory measures.
However, pension fund HAL – with 42 active participants and more than 1,500 workers - does not feature on a list of 25 schemes deemed to be vulnerable by DNB.
The scheme, nevertheless, is afraid that it will be harmed by other developments, such as the pending fundamental update of the Dutch pensions system.
“What would be a solution for most pension funds, could become a – possibly insurmountable – problem to us,” it said.
According to the visitation committee, “the increased burden of regulation raises the question whether the pension fund should consider alternatives”.
The scheme’s board in turn stressed that it wanted to keep the scheme’s set-up as simple as possible.
It acknowledged, however, that fundamental system changes had led to increased complexity and insecurity, adding that it was looking at the options to remain independent.
In a comment, a spokesman for DNB said that “every scheme that is able to keep on complying with the increased demands from their participants, society and the legislator is futureproof, as far as we are concerned. However, we see that small schemes in particular must put in extra effort to keep on top of it.”
He made clear that small pension funds must explain how they see their future.
“But this is not because we think they should liquidate, but because we need to investigate and address their vulnerabilities,” he added.
At year-end, the coverage ratio in real terms of the Pensioenfonds HAL stood at 142%, which means that the chance of a rights cut was less than 0.2%.
The investment policy of the Pensioenfonds HAL is aimed at generating cashflows for the real pension benefits over the next fifteen years.
Last year, it had an investment mix of 59% equity, 14% government bonds and 27% cash.
The overall return was 3.3%, against 10% over 2015.
The pension fund reported implementation costs of €141 per participant for 2016. It spent 0.68% of its average assets on asset management.