New Proposals for Pension Books
for pension accounting rules — and that may clobber employersf
budgets.
Girard Miller |
May 20, 2010 - Governing
The Governmental Accounting Standards Board (GASB) is preparing
to release officially its Preliminary Views on its controversial pension
accounting project in June. A current posting on its website with "tentative
decisions" tells us to expect some big changes with huge financial impact,
if their current thinking works its way ultimately into the accounting
standards.
Those who follow pension finance closely know that there's been a big
discussion about whether to show public pension liabilities on the employers'
financial statements, and if so, then how to value the liabilities.
Traditionally, pension liabilities have been disclosed in the footnotes rather
than on the employers' books. The unfunded liabilities are massive, on the order
of magnitude of $1 trillion for pension funds and another $1½ to $2 trillion for
retiree medical plans (so-called OPEB for "other post-employment benefits"). In
California, for example, these unfunded liabilities are equal to the entire
outstanding bonded debt of the state and its subdivisions. And the numbers could
be even larger. Pension funds have traditionally calculated the present value of
the liability for future pension payments using the expected investment return
from their portfolio assets. A new school of financial economists has argued
that this is too optimistic. Their focus is on the "market value of liabilities"
(MVL). They claim that the discount rate should be the "risk-free" rate like a
government bond, which would make the liabilities look much larger than they do
today.
GASB is seriously considering a middle way that reflects a pragmatic and
reasoned approach. Their tentative view as posted on their website is that they
would use the expected investment return for assets in the pension portfolio for
those assets, but only for those assets. Any liabilities that cannot be paid
from the pension fund assets so invested would henceforth be valued using a much
lower discount rate that reflects the employers' borrowing costs. The discount
rate they mention on their website is a tax-free high-quality municipal bond
index rate, which will be controversial as I shall explain below. That rate
today would be something around 5 percent and not the 8 percent presently used
on average for the portfolio rate. As a result, pension liabilities would be
much higher under the new math. (Remember that the discount rate is raised
exponentially in the denominator of a stream of future values, so a larger
discount rate reduces the projected liability).
GASB's rationale is that the pension fund is the "primary obligor" for the
pension liabilities, but the employer is the "secondary obligor" for those
future liabilities for which the pension fund lacks sufficient assets. Thus, the
discounting at the employer's borrowing rate makes sense for that (secondary)
component of the liabilities to be shown on the employer's balance sheet. After
all, the pension funds can do little to change that portion of the liabilities
through actions of their own — they don't control the employer contributions. So
the pension funds really don't have a primary voice in that part of the
governmental accounting discussion; it's really an employers' issue. (In fact,
GASB cannot require pension funds to use this new methodology in their actuarial
practices; it primarily provides standards for how the costs are recorded by
employers. However, some states require that contributions be made in accordance
with GAAP, and most employers presently follow that practice.)
For the record, I believe GASB would be wiser to use a taxable municipal bond
index rate for the discounting calculation. That would reflect current reality,
since state and local governments are prohibited by federal law from ever
issuing tax-exempt bonds to finance pension obligations anyway. Ever since 1986,
all pension obligation bonds must be issued as taxable. An imputed taxable
municipal bond rate today would be around 6 percent, which would still raise the
pension liabilities, but far less painfully for the employers under this new
accounting convention. Ironically, it would reduce the actuarial liabilities for
OPEB plans that are presently unfunded, so the long-run budgetary impact for
many employers would be neutralized.
Finally, here's the real zinger: GASB has decided to address the issue of
intergenerational equity by correcting a long-standing problem in how long these
liabilities can be paid off. The accounting technique is called amortization.
Presently, GASB allows pension funds to amortize (pay down) their unfunded
liabilities over a period as long as 30 years — even though most employees now
on the payroll will retire long before then, and many retirees will be deceased!
The corporate accounting board (FASB) requires such liabilities to be amortized
over the average remaining service lives of the employees, and GASB is
reportedly moving in that direction as well. Most public employers have a
workforce with an average remaining service life of 12 to 15 years, reflecting
career spans of 25 to 30 years on average plus high levels of seniority in aging
Baby Boom workforces. So this rule alone could potentially cut the amortization
period in half, which almost doubles the annual cost for this aspect of the
liabilities.
Mathematically, it doesn't take a genius to figure out what all this means
for public employers. Annual pension budget costs will increase significantly if
these rules become effective (probably 2013 at the earliest, judging from the
project timetable and past implementation practices). First, the unfunded
actuarial accrued liabilities (UAAL) for pensions will increase by 30-33 percent
for most employers by cutting the discount rate. Then, the amortization period
for most employers will be reduced materially. The cumulative result will be an
increase in annual costs to amortize the unfunded liabilities (which already
doubled in the past recession), by 150-200 percent above current
levels.
Imagine you bought a house five years ago with a 30-year fixed mortgage and
were transferred involuntarily to keep your job; you had to move to a more
expensive city where the same house now costs twice as much and were then told
that the only available mortgage is for 15 years. Then imagine what would happen
if the value of your new house fell in a slumping property market so that your
home equity is eroded. That's essentially the situation facing today's state and
local governments in their pension plans. They now realize they need a smaller
house.
Note that normal costs for current service of current employees would not be
significantly affected. We're mainly talking about the costs to pay for services
previously rendered. But that often represents half of the pension bill, and in
some plans with shrunken or older work forces and large retiree rolls, it's the
lion's share of the costs already. So the impact will vary from employer to
employer and state to state. But the direction is unmistakably uniform: Costs
are going up.
Pension costs are heading higher anyway because of the investment losses the
plans' portfolios sustained in 2008. Most employers will begin to feel those
impacts in 2011 and 2012. Where "actuarial smoothing" has been used too
liberally, the true budget impact has been deferred to 2013. The GASB changes
would redouble or even triple those oncoming cost increases.
Those who believe that we've just been "kicking the can down the street" for
years will rejoice that GASB is finally addressing some major deficiencies in
the current accounting model. Those who find themselves cutting services,
payrolls and salaries for another decade to pay these bills will probably be
less cheerful. Those who get laid off or furloughed endlessly to pay for
irrevocable pension bills incurred by elderly workers will be completely
humorless. If anything brings to light the unsustainable nature of past pension
promises, this will be it, regardless of which side you're on.
The MVL crowd of financial economists will still complain that their views
were not adopted, but that becomes a largely academic point now. The financial
impact of GASB's new approach has far broader significance in cleaning up the
books, encouraging sound funding practices, and establishing genuine
intergenerational equity than the MVL crowd ever dreamed. I'd rather see GASB
take the approach it has chosen, than to adopt a theoretical approach that
creates its own separate set of problems including potential overfunding and
pension raids by public employees and retirees in the future.
GASB's due-process agenda will take many, many months to complete this
project. Their preliminary views are just that — preliminary — and they may
change course in the exposure draft of their final standards in 2011. But those
who are interested in commenting on these ideas should get a copy of their
official Preliminary Views document in June when it's released, and submit
comments or attend an October public hearing.
Public managers who now see that the light at the other end of this tunnel is
an oncoming train will be wise to begin preparing their elected officials and
employee groups for an inevitable cost increase that will require further
retrenchments — even when the economy begins to produce additional revenues.
Smart managers will have their actuaries calculate the numbers this year using
the tentative GASB formulas, to see how large the fiscal impact could be. Other
than the double-dips of 1982 and 1937, this may be the first economic expansion
in American history in which the payrolls of state and local governments
nationwide are cut while the economy is growing.