Why the latest PBGC premium increases may well speed the DB system to its death bed
December 12, 2013 - Russell Investment GroupBob Collie
The Bipartisan Budget Act of 2013 (BBA), announced on
December 10, proposes significant increases in PBGC premiums for single-employer
corporate pension plans. This could be seen as just one more blow among many to
a beleaguered DB system. But it may well be more than that.
The corporate defined benefit (DB) system is, of course, well past its
youthful, growing phase. It has long since been overtaken by defined
contribution in terms of total assets. It
probably hit its peak liability value a year or so ago, so itfs a system
that is already in widely-acknowledged decline. But when the obituary of the
private sector DB pension system is finally written, history may well conclude
that the political opportunism of BBA sped it to its death bed.
There are two reasons I say this. One: it is a big increase. It is a big
increase that follows on from another big increase just one year ago, as part of
MAP-21. The impact is significant: a plan with 2,000 members and a $10m funding
shortfall would have paid $160,000 in 2012; that figure was due to rise to
roughly $280,000 in 2015 under MAP-21fs revised schedule; under BBA, itfll be
$344,000 in 2015 and $408,000 in 2016.
Together, MAP-21 and BBA are going to make PBGC premiums one of the
largest—possibly the largest—costs of running a DB plan. PBGC premiums will
overtake investment management fees in many cases.
The concept of insurance via a government agency only really worked as long
as the cost of insurance was small enough to be a marginal consideration in plan
decisions. At the new levels, itfll be anything but marginal. It will be a
material consideration in a number of sponsor decisions.
With the per-participant premium rising to $64 in 2016, plan sponsors will
have a significant incentive to shed participants through the payment of lump
sums to terminated vested employees and annuity buyouts for retirees.
With the variable rate premium rising to 2.8% of shortfall by 2016, plan
sponsors will have a significant incentive to fund up the plan: only
corporations with an unusually high cost of capital will find it advantageous to
delay contributions.
And, of course, when you add these together, therefs a big incentive for plan
sponsors to revisit the question of whether they really want a DB plan at
all.
The second reason I believe that this legislation will have a big impact is
that it is blatantly political in nature. The PBGC—which reported a $27.4
billion shortfall in its single-employer program as of 30 September this year—is
no doubt happy to receive this boost to its finances. But therefs no real doubt
here that the motivation for the premium increase is the need to balance the
government budget. If this were really about the PBGC, it would involve steps to
buoy up the multiemployer program, which is in far worse shape than the
single-employer program. So this legislation does not originate in a desire to
protect plan participants or to ensure the robustness of plan funding or even to
strengthen the PBGC. It treats the PBGC as a pawn in the political game. Plan
sponsor resentment of the PBGC—which was already high—may become
irreparable.
To strengthen this sense of political cynicism, it is far from obvious that
PBGC premiums serve any purpose in actually balancing the budget at all: even
though the Congressional Budget Office is counting the premiums as revenue, the
PBGC is an independent government agency and there is no government guarantee of
its funding position. Ifm no expert on federal accounting practices, but PBGC
assets do not seem to me to be government assets and PBGC liabilities do not
seem to me to be government liabilities. The government does not control how the
money raised is to be used; the premiums go into the PBGC coffers. So if anyone
is able to explain exactly why PBGC premiums have been counted as revenue for
the purposes of MAP-21 and now BBA, please let me know (and I will pass that
explanation on to everybody else).
All of which will make the increase harder for plan sponsors to buy into. In
short, this is a significant increase in cost, made less palatable by its
political origins. That could prove to be an ugly combination.