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October 2003

Rules/Regs:Missing the Forest

Has Washington dropped the ball on ERISA reform? Some leading critics think so

Has Washington dropped the ball on ERISA reform? Some leading critics think so

» More Debates

» Temporary Measures

» Out of Employees' Pockets?

» "Serious" Reform

Call it Enron II—the second time in two years that pensions have been at or near the top of Washington's agenda. Lawmakers and regulators have spent the session deliberating on a flock of new pension-related proposals. "I'm pleased that pension issues rate higher on the scale," says David Certner, federal affairs director at the AARP. "The disclosures about Enron, the economic downturn, the problems with cash-balance plan conversions have all helped create a great deal more sensitivity on pension issues in Congress and the electorate. They used to slide under the radar a lot more easily."

However, a number of pension experts and policy players fear that the chance for broad reform of ERISA—and perhaps creation of a brighter future for defined benefit plans—is being dissipated.

Some blame the Bush administration, which they say spent the past two years dithering over how to solve the serious problem of how to replace the 30-year Treasury used to calculate employers' pension contributions, only to emerge with an inadequate and unworkable solution. That has left Congress scrambling to take action on the discount rate issue at a time when many pension plans are in crisis rather than deliberating carefully on what is best for ERISA plans in the long run.

"I understand it's only in the last couple of weeks that Treasury's begun to study how to construct an alternative to the current discount rate structure," says Mark Ugoretz, president of the ERISA Industry Committee, after House committee hearings in mid-July. "They've had since 2001 to deal with this issue and they just let it slide."

"The funding rules in general need to be rethought," says Norman Stein, Douglas Arant Professor of Law at the University of Alabama School of Law. "It doesn't make a lot of sense to me to lift out the interest rates used for certain funding purposes and say we have to correct those, without looking at the entire scheme."

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More Debates

Congress and pension regulators are simultaneously debating a slew of other pension-related issues. However, the seeming emergency over the discount rate structure threatens to allow some contentious measures either to slip through without enough debate or to die an obscure death, further limiting the possibility for broad pension reform. Among them:

The proposed Pension Preservation and Savings Expansion Act, currently the House vehicle for a discount rate change, also would change the benchmark for figuring lump-sum payouts from defined benefit plans. Supporters say the shift to a corporate bond composite rate would eliminate a windfall to departing workers; opponents say it unfairly would force some workers to foot part of the bill for bailing out troubled plans.

Another provision in the bill, sponsored by Representatives Rob Portman (R-Ohio) and Bill Cardin (D-Maryland), would allow companies to apply a new mortality table to their pension contributions that projects shorter life spans for blue-collar workers. The probable result: lower pension contributions for plans in rust-belt industries. However, critics are asking why the bill does not incorporate calculations that show white-collar workers live longer.

The post-Enron push for greater disclosure of information about defined benefit plans' financial condition seems to be running out of steam. The pension proposals introduced by the Treasury Department in July that included requiring plan sponsors to assess and publish the termination value of their plans each year met with little support.

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Temporary Measures

The issues raised by these recent developments provide plenty of fuel for a full-fledged rethinking of ERISA itself. Nevertheless, Congress' main concern at present—including a series of late session hearings by the US Senate Subcommittee on Financial Management, the Budget and International Security—is the need to replace the 30-year Treasury as the benchmark for calculating pension contributions.

"A temporary solution may be necessary here," says Certner, "but to make long-term policy in that environment may be the wrong thing to do." Instead, he says, "We should spend a couple of years and see if there are some long-term changes in the economy and we get a better view of what problems we have to address."

"We're very concerned about making a significant change to the funding rules that would impact the system as a whole and individual companies' willingness to sponsor plans. That concern relates to the yield-curve approach," says Sean O'Brien, legislative field director at the AFL-CIO.

Finding agreement on what the permanent replacement should be will be difficult, however. Ugoretz would like to see the corporate bond composite made permanent. The Economic Policy Institute is proposing a new benchmark composed of a 20-year average of 10-year Treasury bonds, which it argues would better reflect the purpose of a pension fund. Stein, too, would like to see the government stick with some combination of Treasurys, because Treasurys are essentially riskless securities—and a stream of guaranteed pension payments is not supposed to reflect the value of a corporate securities portfolio.

However, Stein is reluctant to see a definitive decision made at a time of unusual difficulty for many pension sponsors. Instead, he suggests perhaps temporarily dropping the required funding level to 90% or 80%, installing a more liberal contribution waivers policy, and appointing a "base-closing commission" to develop a long-term solution for Congress.

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Out of Employees' Pockets?

More disagreement can be expected on the issue of altering the discount rate for valuing lump-sum pension payouts. Holding the lump-sum discount rate in sync with the overall pension funding standard has wide support. ERIC, the American Benefits Council, and even some unions are pushing for it. Ron Gebhardtsbauer, senior pension fellow at the American Academy of Actuaries, suggests employees who take a lump-sum payout are currently getting a subsidy and that, with the change, they still would receive a good benefit.

However, not everyone agrees. "We're willing to support some funding relief, but we disagree that it should come out of the employees' pockets if they choose a lump sum," says Certner. The difference can be substantial. For a 45-year-old, a move to a discount rate that is 1% above the 30-year Treasury rate can make a difference of 25% in benefits, Certner says.

Portman-Cardin also has heated up a new discussion by giving plan sponsors leeway to use the new mortality tables with their lower life-expectancy estimates for blue-collar workers. Stein also questions whether worker demographics are the best measure of a company's ability to pay promised pensions—the same issue which has brought so many disparate players to consensus about the need to replace the 30-year Treasury. "Shouldn't the creditworthiness of the company be of concern?" he asks.

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"Serious" Reform

"Whatever it is, it isn't going to be a permanent fix anyway," says Stein. "People will be coming back a couple of years from now, asking for the corporate bond rate plus 2%, or a junk bond rate instead of top-rated bonds. We're making policy based on a very unusual point in time."

Others fear that a temporary solution, plus the individual breaks that some industries are clamoring for, could make it more difficult to make good overall pension policy a few years from now. "I think we should rewrite the rules in a serious manner, not for specific industries," says Weller.

At stake may be the prospect of rebuilding defined benefit plans' viability at a time when workers find them increasingly important. "Our real concern about the defined benefit system, and our concern about a proposal like the administration's, is that changing one piece in a major way, without changing pension funding in a much broader way, will lead to companies getting out," says the AFL-CIO's O'Brien.

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Eric Laursen
editors@plansponsor.com









 

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