In a recent Cash Balance survey from October Three, the focus to a large
extent was on interest crediting rates used by plan sponsors in corporate cash
balance plans. In large part, the study shows that those methods are mostly unchanged over the past 20 years or so, this, despite the passage of the
Pension Protection Act of 2006 (PPA) that gave statutory blessing to a new and
more innovative design. I look briefly at what that design is and why it
is preferable for plan sponsors.
Prior to the passage of PPA, some practitioners and plan
sponsors had looked at the idea of using market-based interest crediting rates
to cash balance plans. But, while it seemed legal, most shied away, one would think,
due to both statutory and regulatory uncertainty as to whether such designs could
be used in qualified plans.
With the passage of PPA, however, we now know that such
designs, within fairly broad limits, are, in fact allowed by both statute and
regulation. That said, very few corporate plan sponsors have adopted them
despite extremely compelling arguments as to why they should be preferable.
For roughly 20 years, the holy grail for defined benefit
plan, including cash balance plan, sponsors has been reducing volatility and
therefore risk. As a result, many have adopted what are known as liability
driven investment (LDI) strategies. In a nutshell, as many readers will know,
these strategies seek to match the duration of the investment portfolio to the
duration of the underlying assets. Frankly, this is a tail wagging the dog type
strategy. It forces the plan sponsor into conservative investments to match
those liabilities.
Better is the strategy where liabilities match assets. We
sometimes refer to that as investment driven liabilities (IDL). In such a
strategy, if assets are invested aggressively, liabilities will track those
aggressive investments. It’s derisking while availing the plan of opportunities
for excellent investment returns.
I alluded to the new design that was blessed by PPA. It is usually referred to as market-return cash balance (MRCB). In an MRCB design, with only
minor adjustments necessitated by the law, the interest crediting rates are
equal to the returns on plan assets (or the returns with a minor downward
tweak). That means that liabilities track
assets. However the assets move, the liabilities move with them meaning
that volatility is negligible, and, in turn, risk to the plan sponsor is
negligible. Yet, because this is a defined benefit plan, participants retain
the option for lifetime income that so many complain is not there in today’s
ubiquitous defined contribution world. (We realize that some DC plans do offer
lifetime income options, but only after paying profits and administrative
expenses to insurers (a retail solution) as compared to a wholesale solution in
DB plans.)
When asked, many CFOs will tell you that their companies
exited the defined benefit market because of the inherent volatility of the
plans. While they loved them in the early 90s when required contributions were
mostly zero, falling interest rates and several very significant bear markets
led to those same sponsors having to make contributions they had not budgeted
for. The obvious response was to freeze those plans and to terminate them if
they could although more than not remain frozen, but not yet terminated.
Would those sponsors consider reopening them if the
volatility were gone? What would be all of the boxes that would need to be
checked before they would do so?
Plan sponsors and, because of the IDL strategies,
participants now can get the benefits of professionally and potentially
aggressively invested asset portfolios. So, what we have is a win-win scenario:
very limited volatility for sponsors with participants having upside return
potential, portability, and wholesale priced lifetime income options.
The survey, as well as others that I have seen that focus
on participant outcomes and desires, tells us that this strategy checks all the
boxes. Now is the time to learn how 2018’s designs are winnersfor plans sponsors and participants alike.