Monday 17 August 2015

The Key Challenges of Nigerian Pension Industry and Possible Solutions–From an Actuarial Perspective





Presented By

Dr. Pius Apere (PhD / FCII)
(Actuarial Scientist/Chartered Insurer)

Deputy Managing Director
Linkage Assurance Company PLC
Tel: +234(0)7086438525

August 2015


Introduction
Nigerian Pensionershave high expectations on the new Government to ensure an effective implementation of pension regulations existing in the country. These expectations arise from the need to have sustainable standard of living in retirement and their benefits paid as at when due.

The different pension regimes operating in Nigeria,Defined Benefit (DB) and Contributory Pension (CPS) Schemes, give rise to varyingset of problems that limit the capacity of key stakeholders within the Nigerian pension industry to meet pensioners’ expectations.

The key stakeholders in the pension industry can be grouped into four categories, namely the regulator (National Pension Commission (PENCOM)), pension operators (Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs)), contributors (employers including the Government and employees) and beneficiaries (Pensioners).

This paper highlights the key challenges facing the stakeholders in the pension industry and the possible solutions from an actuarial perspective.In broad terms, the challenges arising from different areas of pension management include but not limited to the following: Transitional Pension Management, Guaranteed Minimum Pension, Additional Voluntary Contributions, Pension Protection Fund, Investment Guidelines, Public Education and Enlightenment, Pension Database, Risk Management and Human capacity development.

Transitional Pension Management
Key Challenges
The current problems that beleaguered pensioners from Pay-As-You-Go (PAYG) defined benefit (DB) scheme in Nigeria (which have always been to the fore) include, inter alia:

·         Delayed or non-payment of pension entitlements.

·         Misappropriation of existing pension funds(existence of ghost pensioners).

·         Low standard of living or high poverty incidence among pensioners due to pension increases not in line with salary inflationin the economy or no pension increase at all.

·         PENCOM has mandated Pension Transitional Arrangements Directorate (PTAD)(section 42 of PRA 2014) to regularly verify the pensioners registered on its database with a view to determining their ‘Alive Status’. That is, to conduct, at least annually, continuous verification of already verified pensioners. Too frequent verification of pensioners leading to pensioners dying during verification exercises.

·         Inadequate, incomplete, misleading pension information being provided to pensioners.


·         Inadequate Enforcement of Pension Regulation– Over 10 years of existence of CPS, not all State Governments had enacted their pension Laws to establish CPS which is a sign of regulatory weakness. The actuarial valuations required by PENCOM at the point to disengage the old DB scheme in order to implement the CPS have not been carried out even for those Government public service schemes that have already established their CPS.

Possible Solutions
The establishment of PTAD and various penalties for pension funds mismanagement introduced by PRA 2014 would address some of the lingering challenges of pensioners in the public service pension administration in the country.

However, below are other ways to address the problems described above:

·         Create pensioners’ biometric database that is suitable for future actuarial valuation, demographic and financial projections, which would also eliminate ghost pensioners.

·         Adopt a pragmatic approach to pensioners’biometric verification process (a system of self-verification by pensioners capable of automatically updating the pensioners’ database) having conducted an initial face-to-face verification in order to minimize the frequency of subsequent face-to-face verification exercise.

·         An automation of pension/gratuity calculation and payment system to ensure thatpension increases are implemented on a timely basis relative to increase in workers’ salaries and also allowingpensioners to receive their pensions/gratuities as at when due. The Integrated Personnel and Payroll Information System (IPPIS) for the Federal public service should be emulated at the State and local Government levels,

·         A periodic actuarial valuation of the old DB pension scheme as required by law needs to be carried out in order to ascertain the value of the pensioners’ liabilities at a given date as the scheme runs off. This will enable a realistic annual pension budget estimate to be made for the Government(s) which will reduce the insufficient funds being allocated for pension payment. This would help in the administration of PTAD in minimizing the delays and arrears in pension payment.

·         PTAD should set up a realistic pension stabilization fund (to be invested) with the primary aim to stabilize the pension/gratuity payment system which is always in arrears. This will ensure that money is readily available to pay the arrears of pension liability.

In summary, the relevance of professional actuaries and information technology experts cannot be ignored in the implementation of the above suggested solutions.





Guaranteed Minimum Pension (GMP)

Key Challenges

Theguaranteed minimumpension (GMP), which will be specified from time to time by PENCOM, is a provision for protecting all Retirement Savings Account (RSA) holders who have contributed to a licensed Pension Fund Administrator (PFA) for a number of years but have not accumulated enough to have a decent standard of living in retirement (Section 84(1) of PRA 2014). Thus, it is anincome support from the government, which can be considered as a variant of social security policy that ensures redistribution of resources, to act as a safety net for  pensioners.

The modalities for implementing GMP are yet to be finalized by PENCOMfor more than 10 years after the CPS was established in Nigeria. The above could be attributed to the computational complexities involved in determining the GMPthat require actuarial techniques which might not have been considered importanton the grounds that such pension funds (DC schemes) are seen as pure investment accumulation vehicles.

Possible Solutions
The assessment of the level of GMP to be paid and the cost of guarantees requires stochastic modelling techniques.  This is clearly a task which should be under the control of an actuary and as such PENCOM should obtain the relevant actuarial services. There should be regular revision of the level of GMP in the future.

Additional Voluntary Contributions (AVC)
Key Challenges

There is lack of valuation of an individual member’s DC plan (individual projectionsof likely pension benefit at retirement) by PFAs with a clear objective to measure sustainable retirement income (using metrics such as replacement ratio which represents a sensible estimate of the standard of living in retirement) before allowing an individual to make his/her choice of AVC. The concept of replacement ratio provides an effective connection between the accumulation and de-accumulation phases of a DC plan member’s life cycle.

With the exception of tax benefit, there is also no incentive for additional savings (AVC) towards retirement, particularly where there is a minimum guaranteed pension to be funded by the Government. Thus, there are relatively small RSA balances of some retirees pending the implementation of GMP. This results in a growing sense of disenchantment with the token monthly pension benefit being received by pensioners under the new CPS relative to the huge gains (from investment returns and dividends) the Pension Fund Administrator (PFAs) are currently making.

The above arises from the expectation that all returns on invested funds belong to contributors (employees) except for the minimal fees/chargesexpected for the pension operators. The lack of frequent review of fees/charging structure (including the stipulated fees by PENCOM representing the maximum amounts) chargeable by operators and possible non-disclosure of hidden charges, interests and commissions accruable to pension assets might also be the cause of above dissatisfaction. 

Possible Solutions
The fees/charging structure needs to be constantly reviewed by PENCOM in order to eliminate any hidden charges in order to increase the RSA balances.

There is also a need for sensitization of potential benefits to workers in making AVC having considered the expected living standard in retirement.PENCOM should engage Independent Financial Advisers (such the actuaries) in the sensitization programme.

Pension Protection Fund (PPF)

Key Challenges
PENCOM had been mandated to establish and maintain a fund to be known as the Pension Protection Fund (PPF) for the benefits of eligible pensioners approved or recognized under section 82(1) of PRA 2014. The PPF requires funding by the Government,  PENCOM and Pension Operators but the specific ratio of funding had not yet been fully worked out for the operators (section 82(2) of the PRA 2014).

Indeed, the funding of GMPis the responsibility of the government in other jurisdictions (such as in the UK and Chile, just to mention a few) to ensure that pensioners will not have less than a certain amount to live on. In Chile the cost of fundingthe GMP is expressed in terms of the nation’s Gross Domestic Product (GDP). This metric is more appropriate than a percentage of total monthly wage bill of employees in the Public Service of the Federation (section 82(1)(a) of PRA 2014) since private sector employees in CPS who retiree may also qualify for GMP.

On the other hand, the adequacy of the PPF will be tested if the GMP is fully implemented to take effect retrospectively, therebyallowing all those who have retired since the contributory pension scheme was established in 2004 to qualify for the GMP provided the level of pension in payment is below the GMP to be set by PENCOM.

As employees of organizations with less than three employees as well as self-employees shall be entitled to join the CPS (section 2(3) of PRA 2014), the number of future retirees qualifying for GMP is likely to increase exponentially over time. Thus, there will be a corresponding increase in futureGMP liability which is also likely to put a strain on PPF, having considered the funding methodology in section 82(2) of PRA 2014 in the light of present economic situation in Nigeria.

Possible Solutions
There is likely to be an accrued GMP liability already in existence prior to initial funds being set aside in the Pension Protection Fund leading to an immediate shortfall in PPF. Thus, a periodic actuarial valuation of the fund would be required to ascertain the right level of contribution/levy to be imposed in order to meet the future GMP liabilities.

The assessment of the cost of guaranteesbecomes an issue for capital adequacy and financial management of the PPF and the test of capital adequacy will be carried out on regular basis in line with generally accepted actuarial practice (GAAP).

The number of retirees qualifying for GMP will be reduced if many employees are encouraged to make AVC and this will reduce the strain on PPF.

Investment Guidelines
Key Challenges

Section 86 PRA 2014 makes provision for permissible investment instruments including real estate development investmentsand specialist investment funds (e.g. include infrastructure development),  subject to guidelines issued by PENCOM. The dearth of investment outlets is a major problem facing the pension operators, as it will be difficult to determine an optimal investment mix consistent with risk profile as required by section 78(3)(b) of PRA 2014.

Thus, PENCOM should expedite actions on the proposed amendment to the guidelines on investment of pension assets in order to facilitate the investment of parts of the over N4.5 Trillion pension funds in a bankable infrastructure projects in the country. Expediting actions on the institution of this guideline by PENCOM would, however, ensure adequate protection and safety of pension funds at all times.

Empirical evidence shows that Pension Fund Administrators (PFAs)have continued to invest bulk of pension funds in Federal Government securitiesand money market instruments relative to equities, leading to having investment portfolios that are too risk averse.

In other words, most PFAs are adopting low risk investment strategies without taking into account the individual members’ risk profiles and therefore, in the long term, are likely to result in lower emerging pensions than might have been expected of life-style investment strategies for investment portfolios with different risk profiles. Furthermore, it has been argued that the over concentration of pension funds in debt instruments might be limiting the growth potential of the retirement fund for young pension contributors with long term investment horizon.

The dearth in wide range of investible instruments currently being experienced in the pension industry will hamper diversification within PFAs investment portfolios with the aim to maximize their investment returns, leading to an increase in total pension assets. However, the growth in total pension assets in recent times was as a result of new entrants into the CPS which will lead to consistent guarantee of pension income from older entrants. Furthermore, the yield on investment in real terms has been wiped off by the rising inflation and the devaluation of the national currency.



Possible Solutions

An actuarial advice might be needed by the Investment Strategy Committee, which is to be established by every PFA under section 78 of PRA 2014, in carrying out its functions. Actuaries should typically have a part to play in strategic investment decision-making, bringing to bear skills in asset-liability modelling and stochastic modelling of investment portfolios. In addition, actuaries can also provide PENCOM with an independent assessment of the appropriateness of PFAs investment strategies.

There is also the need to research, structure, develop and invest in alternative asset classes that have the potential to beat inflation sustainably and this has made a case for the use of pension fund to finance infrastructure developmental projects.

Public education and enlightenment
Key Challenges
Actuarial Involvement in CPS

The traditional thinking has been that members in DC schemes bear all the risks and rewards and receive whatever outcomes are produced at retirement. These DC schemes may have the legal ability to adjust member liabilities including contribution rates automatically, as asset values move up or down,therefore limiting the need to immunize asset/liability movements. It is normally assumed that such schemes have limited or no actuarial involvement.

On the other hand, a DCsystem such as CPS operating in Nigeria that forces compulsory contribution rates (section 4(1) of PRA 2014) and entails significant tax concessions (section 10 of PRA 2014) should not, under reasonable circumstances, be left to require members to bear all risks over many decades of membership. Thus, the introduction of guaranteed minimum pension (GMP) in section 84(1) of PRA 2014 is quite appropriatewith the aim to reduce the risk of volatility of standard of living in retirement facing the pensioners.Conceptually, the determination of the GMP and investment strategies to meetaccrued GMP liability requiresan actuarial methodology.

Knowledge Gap

The CPS has been characterized by general misconceptions and knowledge gap. The contributors (particularly employees with low financial literacy level) are either reluctant to contribute to the scheme due to lack of investment knowledge (many workers misunderstand investment returns, expenses, and how each investment vehicle works) or just because they are unaware of the benefits of such scheme.

Lack of professional advice

PFAs and insurance companies are misinforming newly retirees in order to gain undue patronage under the CPS (i.e. de-marketing each other) instead of allowing the retiring workers to freely choose their mode of withdrawing their benefits as required in section 7(1) of PRA 2014.

Thus, lack of professional advice on the choice of pension benefit options at retirement has led to more retirees still opting for programmed withdrawal (94,097 retirees) than life annuity (8,479 retirees) in February 2014. The PFAs have failed in their duty to enlighten the retirees professionally simply because the programmed withdrawal is a product of the PFAs (the preferred withdrawal option recommended) while the life annuity is a product of a licensed Life Insurance Companies.

Furthermore, the lack of professional advice has also led to few workers make AVCs and this will affect their standard of living in retirement.

Provision of inadequate information

Section 55 (d) of PRA 2014 requires PFAs to provide regular information on investment strategy, market returns and other performance indicators to PENCOM and employees or beneficiaries of the retirement savings accounts and yet this is not fully complied with.

Possible Solutions
There should be a regular awareness Campaign/Education to sensitize the RSA holders of the benefits of the CPS by PFAs and the PENCOM.

PENCOM should require Independent financial advisers (IFAs)to advise the RSA holders at retirement date on the choice of benefit options. The advice to take either programmed withdrawal or life annuity should be based on individual circumstances in order to eliminate the asymmetric nature of retirees’ decision making process of being influenced by PFAs to buy more of a programmed withdrawal than a life annuity. Regulators should factor into the overall charges the cost of advice retirees received from IFAs.

Pension database
Key Challenges
Lack of biometric database for RSA holders would not enable the take-off of the transfer window as specified in sections 13 and 14 of PRA 2014. The biometrics capturing project is aimed at ensuring the integrity of data by eliminating multiple registrations, a serious challenge to the pension industry.

Many RSA clients’ profiles on PFA biometric databases were outdated and also not complaint with Automated Finger Identification System (AFIS) standards and specifications. This makes it difficult for RSA holders to move their accounts from one PFA to another and/or also for PFAs to seamlessly treat transactions on such RSAs or communicate with RSA clients.

Section 23(e) of PRA 2014mandates PENCOM to maintain a biometric database on contributors and retirees in a national data bank (NDB) domiciled in-house and verification exercise on the RSA clients’ National Databank is carried out on a regular basis in addition to databases being kept by PFAs for the same clients. Stakeholders are worried about a possible information overload as a result of the multiple biometric and verification exercises that Nigerians were being forced to do (such as those conducted by National Identity Card management commission, Bank verification, Permanent Voters card etc.).

Possible Solutions
PENCOM should be able to link up with thePFAs databases from their data bank and aggregate to give it the desired security identification. The main concern is the verification of information which has been leveraged on the use of cards similar to permanent voters card (PVC). The possibility could be explored in the future to improve on the databank.

PENCOM database needs to be relevant, credible, reliable andappropriate for pension scheme management decisions making process as well as for actuarial computations which would require projections of economic and demographic factors. Therefore, actuarial inputs are necessary elements in the creation of such a database.

Risk Management
Key Challenges
Some pension operators face operational risks associated with receipt of contributions without appropriate schedule, litigations and non-funding of RSA by employers.All licensed pension fund operators are mandated to development, implement and maintain a sound and prudent risk management framework that comprises policies, procedures and processes, appropriate to nature, scale and complexity of their operations.

The overall objective of the risk management framework is to manage the risk of volatility of the standard of living (which could be measured in terms of replacement ratio or real income) that each employee can maintain in retirement by virtue of being a member of the CPS. Thus, the management of this risk is crucial and it is important that PFAs understand this message clearly.

Possible Solutions

An actuarial advice would assist the Risk management Committee (which is to be established by every PFA, as stated in section 78(2) of PRA 2014) in carrying out its functions. In particular, there is a role for the actuaries in projecting the range of pension benefits which could be reasonably and/or realistically expected to emerge from a given contribution rate, taking into account the investment funds selected.

Human Capacity Development
Key Challenges
PENCOM has warned the PFAs and PFCsbased on section 23(g) of PRA 2014to desist from employing contract staff (or use of outsourced staff from third parties who are not properly trained) to perform critical functions such as: pension administration; benefits administration; fund management and accounting; settlement, as well as custodial services, in order to avoid fraudulent activities from third parties.

The regulator (PENCOM) should also have access to actuarial advice in order to be properly equipped to monitor and understand the financial and actuarial conditions of the CPS and pension operator (PFAs), in line with section 24(m) of PRA 2014.

Possible Solutions
Pension operators should set aside sufficient funds from profits in order to invest more in the training of their employees. They need to develop a training programme/calendar on a yearly basis. Thus, indicating the training needs of the employees as well as ensuring that relevant courses are identified for each employee relating to their own areas of operation/expertise.

A well trained work force will help reduce the risk of potential errors, improved the service delivery that adequately meets the needs of clients and improve the morale of employees as he/she will have a sense of belonging, ultimately promote loyalty.

The importance of actuarial expertise required in the management and regulation of pension schemes whether DB or DC schemes cannot be overemphasized and thus, PENCOM should initiate/sponsor actuarial training programmes to solve the problem of dearth of actuaries,as their services are valuable for the management of both pension regimes  in Nigeria.

Conclusion
Thekey challenges facing the pension industry and the possible solutions highlighted above (if considered and implemented by all stakeholders) would form the basis for transforming the Nigeria pension industry to meet the expectation of pensioners and also contribute significantly to the nation’s economic development, leading to an increase in the  GDP.
Dr. Pius Apere (FCII, PhD in Actuarial Science), Deputy Managing Director, Linkage Assurance Company PLC




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