“Most people hope that interest rates will go up so the value of liabilities goes down,” Franceries told PLANSPONSOR. “But with the funding relief, the discount rate is so smoothed (over 25 years) that the liability value is known over the next three years. Liabilities will not be sensitive to rates anymore. This could raise a question if you are in fixed-income investments: if rates go up, your fixed income investments will lose in value, but your liabilities will not move at all.”
That means plan sponsors might have to increase contributions when they could have decreased them had their liabilities been timely marked to market. But the new law could cloud sponsors’ judgment, tempting them to choose very short fixed-income investments to remove interest rate risk, a move that Franceries strongly discourages.
Franceries said a pension fund which appears to be 100% funded due to the new regulations, but is actually 80% funded, might say, “‘Let me switch all my assets to cash. I won’t lose money with cash.’” Franceries does not agree with that logic. “The assets will not appreciate in value, your deficit could stay constant or even increase once the effects of the new bill disappear in a few years," she stated.
The bill presents a problem in the case of decreasing interest rates. Sponsors can now calculate their liabilities based on benchmark bond rates for the 25-year-preceeding period. Because interest rates were much higher before the 2008 financial crisis, the use of higher interest rates lowers pension liability calculations (see “Despite Funding Relief, DB Contributions May Stay Above Minimum”).