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IASB puts up new Exposure Draft on pensions accounting

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The International Accounting Standards Board has put up a new Exposure Draft proposing amendments to the accounting regime for defined benefit pension schemes.

The Exposure Draft is, essentially, the accounting profession’s way of publicly consulting on changes to the accounting standards which govern financial reporting regimes. Like everything else, accountancy is governed by global standards which seek to harmonise how accountants report company accounts; unfortunately, IAS19, which governs how defined benefit pension schemes are accounted for, is subject to the same short-termist approach as the rest of the corporate world, implying that it is inimical to the long-term nature of defined benefit pension schemes. Both it and its predecessor in the UK (FRS17) have been blamed, at least partly fairly, for contributing to the rush to close DB schemes.

The IASB has already been through a lengthy consultation process on its preliminary views on refining how defined benefit schemes are financially accounted for; this new consultation runs until early September this year. The Draft is available for public comment and the IASB aims to finalise its plans by mid-2011, with a view to the new standard becoming effective in 2012 or 2013.

The new Exposure Draft seeks to ‘improve’ (in the context, a word full of dread!) pension scheme accounting by requiring companies:

– to account immediately for all estimated changes in the cost of providing pension benefits and all changes in the value of plan assets

– to use a new presentation approach that would clearly distinguish between different components of the cost of these benefits

– to disclose clearer information about the risks arising from defined benefit plans.

Some of this inevitably needs decoding. According to KPMG, what this means in practice is that companies will henceforth have to stop booking a ‘profit’ in their accounts equivalent to the gap between expected investment returns and the interest cost paid on pensions liabilities. This ‘pensions credit’ is, essentially, a way of recording a paper profit from the pension scheme where schemes’ investment returns are higher – as they usually are, where schemes are investing in equities – than the AA corporate bond yield used to discount liabilities. The introduction of the amendments to IAS19, which will require the assessment of investment returns to be based on the same yield on AA corporate bonds, thus effectively ending the credit, will, clearly, lead to greater transparency in accounts – and, at the same time, to a further reduction in the attractiveness of running DB pension schemes.

KPMG’s press release quotes that this will ‘cost’ UK businesses £10bn in lost earnings, with the largest schemes facing a ‘loss’ of £50m per annum, while the ubiquitous John Ralfe believes that this will ‘cost’ BT £750m (turning a £500m ‘profit’ from the scheme on the existing basis into a £250m ‘loss’ under the new one). Ralfe has a long-standing antipathy to schemes investing in equities – as this blog has previously observed. In terms of the actual cost in individual cases, much would seem to depend on how much schemes have invested in equities – though (perhaps to disappoint Ralfe) this is unlikely to result in schemes adopting more cautious investment profiles in the interim.

Will it make much difference? Yes, clearly, to those schemes which remain open to future accrual (the BTPS among them): changes in accounting rules which take money away from the profit and loss account – however much such money was paper only, and regardless of whether pension schemes should have been used in this way to boost earnings – will have an impact on ordinary workers since that ‘profit’ will have to be found from elsewhere so as to retain the level of earnings. Whether it will lead to more schemes being closed, given the numbers of schemes which have already come crashing down and the weight of other arguments against running DB provision which already exist, is a moot point.

Certainly, however, it – together with the requirement for further ‘clarity’ on the risks associated with defined benefit provision – can’t help; I’m almost of the view that it’s the latter that is the most damaging feature of all this: regardless of the ‘losses’ which need to be made up, having to write (or read) even more stuff in company accounts about just how much risk is posed by running a defined benefit scheme may well end up wearing down even the most resilient of corporate defenders of DB provision.

Clearly, these remain tough, and worrying, times for DB schemes, and most of all for the members of them.


Written by Calvin

30/04/2010 at 6:19 pm

Posted in Pensions

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Ralfe has a bit of a go

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Today’s Financial Times highlights some of the results of a report by pensions consultant John Ralfe for TalkTalk, BSkyB and Cable&Wireless on the Ofcom Pensions Review, the first stage of which closed last week.

Ofcom has now started to publish the non-confidential responses – including that by the Connect Sector of Prospect – (follow above link, or go here) but while each of the three companies’ responses refers to the Ralfe report as having been provided to Ofcom, it doesn’t unfortunately appear on the site, and Ralfe’s own website appears to be a little shy of carrying it just yet. That’s a bit of a shame as I’d like to see it – though perhaps it is a private report (in which case its use in a public policy-making process is, perhaps, somewhat limited).

The pink’un‘s report indicates two issues that Ralfe has highlighted:

1. BT hasn’t paid the full costs of its early leaver programmes;

Ralfe costs these at £3.2bn and contrasts this with what he says BT paid into the scheme (£1.1bn). The £1.1bn is easy – that comes from BT’s accounts, helpfully summarised in Table 5, p. 41 of the Ofcom consultation document, while the £3.2bn is a product of Table 5 and Table A3 – essentially, it is the accounting charge figure for the costs of the release schemes.

But how does Ralfe know that BT hasn’t paid these costs in full? The accounts may well provide a specific cash figure for what BT has paid in release programmes – frequently as a result of specific requests from the trustees and as a result of what actuaries at the time said was the cost of such programmes – but BT has paid more than £3bn in additional special contributions since 1990. The need for additional special contributions has a number of reasons, including people living longer in retirement, investment returns being less than envisaged requiring what we now call a recovery plan to be put in place, changed actuarial assumptions – and, as Ofcom points out in para. 5.56, the effect of early release schemes.

The point is that BT has had to stump up such costs out of its other operations whereas, in reality, it is a normal business cost that should have been present in its regulated costs all along.

2. And the scheme was £626m in deficit on privatisation and BT should have dealt with this by putting its money into index-linked gilts.

The figure for the size of the deficit is new – we were aware that, in the words of the valuation of the scheme prepared in advance of privatisation, ‘The resources transferred were not sufficient to meet the liabilities assumed by the Scheme’. There was a deficit in the Post Office Staff Superannuation Scheme at the time and, thus, the newly-established BT scheme essentially assumed a share of this. According to the FT, Ralfe obtained this figure via a FoI request – and he’s done helpful work here. (By the way, £626m in 1984 was a huge sum – a real millstone hung by BT’s privatisers around the neck of the company, equivalent to around £1.5bn at 2007 prices.)

Ralfe’s long-held view is that all pensions assets need to be invested in risk-free vehicles – the source for his belief that the BTPS would now be £4.5bn better off. Indeed, while he was at Boots, he pioneered a switch of assets entirely into bonds – a move which has, since his departure, been at least partly reversed (as I blogged about here). Interestingly, the valuation published in March 1986 held that the assets were – in the rather more imprecise language of pensions valuations in the times – ‘now very nearly sufficient to meet the cost of benefits’. So, investing in equities had ‘very nearly’ (!) wiped out the deficit in a couple of years.

The difficulty that Ralfe faces in rationally sustaining his charge here is an old one, of which he is likely to be well aware – pensions are long-term investments and measuring their worth at any particular period of time – or between any two periods of time – essentially gives only a snapshot picture. And one that is more or less useful, depending on the assumptions made and the time at which they were made. In December 2008, the assets of the BTPS, according to the scheme’s annual report and accounts, stood at £31.3bn; one year earlier, they had stood at £39.7bn. So, assuming that the scheme would, on current figures, be £4.5bn better off had it invested in index-linked gilts since privatisation ignores that it would have been pretty much about the same amount worse off had the current figures reflected the December 2007 situation rather than the December 2008 one. And, of course, there has been a stock market recovery since December 2008 and the asset base of the BTPS is now likely to be in much better health as a result.

These remain difficult times for the BTPs, as for all schemes – and they are ones that are not likely to be beneficially confronted by precipitate actions of the type recommended by Ralfe.

As for the Regulator, the point facing it is, essentially, one of principle: should a regulated company be able to recoup the full costs of providing its regulated products and services, even though some of those costs might not appear until later? There can only be one answer to that.

Written by Calvin

01/03/2010 at 7:03 pm

Heat and light and the BTPS deficit

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Today’s announcement of BT’s third quarter results was accompanied by the long-awaited outcome to the discussions between the company and its trustees on the most recent triennial valuation, due at the end of December 2008.

In brief, the upshot is that the scale of the deficit – as at December 2008 – is some £9bn and that the company has agreed with the trustees of the scheme to make annual payments to clear the deficit as currently envisaged over the next 17 years, starting with £525m per year for the next three years, increasing to £583m in the fourth year and indexed by 3% thereafter. The Regulator, however, which has also been involved in aspects of the discussions up to this point, has concerns over parts of the agreement and will be undertaking its own review of the recovery plan.

The news was greeted rather poorly in the barrowlands of the City, with the results of the day’s share trading activity seeing an 8.6% drop in the value of the company, taking it to a market capitalisation of £9.3bn – just a little over the size of the deficit, incidentally (and some 30% of the asset value of the BTPS). This is despite BT making sufficient free cash from its operations to support a recovery plan of that scale:

This is a prudent valuation and a recovery plan which re-affirms BT’s commitment to meeting its pension obligations. The operational improvements we are making in the business are generating sufficient cash flow to support the pension scheme whilst allowing us to pay dividends, invest in the business and reduce debt. (quote from Ian Livingston, BT  Chief Executive; same link as above)

At the same time, the news was accompanied by an announcement that the trustees of the scheme are to seek a court ruling to clarify the precise scope and extent of the Crown Guarantee given to the members of the scheme on privatisation back in 1984. The question of the Crown Guarantee was examined in today’s Peston’s Picks and it is here where the most heat has been generated (not Peston’s fault – I’m thinking of the uninformed and prejudiced comments on his blog post).

The key lack of understanding here surrounds the circumstances of the Crown Guarantee coming into play – i.e. an insolvent BT with insufficient assets to meet the debts of the scheme. It has to be admitted that such a circumstance is an evidential possibility – but it remains an extremely remote one. The question of how much of the total amount of the debt would then fall on the taxpayer as a result of the Crown Guarantee is the subject of the court case since it may not be all of it – we simply don’t know. The £9bn current deficit is thus, from the point of view of the state, very much a worst case scenario. The circumstances around why the case is being taken now are likely to reflect BT’s contributions to the Pensions Protection Fund and the role of the Crown Guarantee in reducing these which resulted last year – one year ago to the day, coincidentally – in the announcement of the outcome of a European Commission investigation on the grounds of state aid.

The accepted debt of £9bn would put the BTPS’s funding situation at about 79.5% (remembering that this is the picture as at the end of December 2008 – i.e. immediately prior to the rise in the stock market over 2009 which would have inflated asset values).

The Pensions Protection Fund has recently produced the 2009 edition of its Purple Book which provides a comprehensive indication of the state of health of defined benefit pension schemes as at the end of March 2009 – so, more or less similar to the end of the period covered by this BTPS valuation. The Purple Book‘s estimate of the overall funding position of schemes at that point was also 79.5%. Thus, the BTPS was no worse off than the average scheme at that point. It looks worse, because of the size of the deficit which, according to Robert Peston, is a record – but that’s because of the sheer size of the scheme. Given its size, the size of the deficit is, actually, in line with what you might have expected given the average state of health of schemes generally.

The scale of the overall deficit in March 2009 – some £200bn – has, in the nine months in the interim, been reduced to £52bn, indicating an overall funding position of 94% based on total scheme assets of £860bn. The BTPS is also likely to have seen a rise in its funding position in this period although this – and the exact scale of the recovery – is clearly open to conjecture.

Will BT have to pay back this total £9bn – possibly, if the actuaries have their sums right. Depending on the outcome of the next valuation, it may be less than this if stock market recovery continues (or if some of the other assumptions underpinning the valuation change). Of course, that’s an uncertain bet. But if it does, the next valuation will indicate a different basis for the amount to be recovered (and, perhpas, the period over which it needs to be done).

Pensions are long-term investments and the difficulty with valuations is that they provide only snapshots of what is a continually changing picture. Once the regulator has conducted its review of the recovery plan, the reasons for its concerns may become clearer. But, what matters for now is that BT believes the recovery plan to be fair and that it is capable of meeting the costs of this – that, and that the trustees of the scheme are content with the strength of support of BT as scheme sponsor.

Written by Calvin

11/02/2010 at 5:37 pm

Posted in Pensions

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Ofcom consultation on BT’s pension costs: apoplexy in west London*

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Ofcom yesterday published its previously-trailed consultation on whether BT’s regulated wholesale prices should in the future include any costs in respect of deficit repair contributions to its pension scheme, whether there should be some changes or whether things should stay pretty much the way they are (which is that BT’s reported pension service costs, as measured by the IAS19 accounting standard, can be included in the assessment of its costs).

So far, so usually esoteric Ofcom stuff. But the announcement of its consultation was greeted with consternation by BSkyB and Carphone Warehouse, who promised in newspaper reports to resist the ‘plain wrong’ move ‘as hard as we can’. Here, we should note that the consultation is not only open for business, so to speak, but is open-minded: Ofcom has not yet decided to do anything other than to ask the question of whether or not this is a good idea.

The essential background both to the move and to the consternation with it was greeted by BT’s rivals largely consists of two factors: in other industries (e.g. water and energy supply), regulated bodies are able to take into account deficit repair costs; and the size of the deficit in the BTPS (and, consequently, the scale of BT’s repair costs). No doubt Ofcom would not have chosen this point in the BTPS deficit cycle – when the deficit is likely to be at its height (‘likely’ because the actual deficit, not the one measured by accounting standards, is not yet known) – to have launched such a consultation. The timing here is not entirely of its own making, however, since this issue (specifically, the discrepancy with how other regulators view the issue of deficit contributions) cropped up in BT’s response to the Ofcom consultation earlier this year on the pricing framework applicable to Openreach.

The concerns of BSkyB and Carphone Warehouse are, in one respect, evident enough: their costs as customers of BT will rise. Of course, the costs of all such industry customers of BT (including those of BT Retail, BT’s own customer-facing business) will rise, and by the same amount, so the issue is not one of a loss of competitive position but one of how those costs are then dealt with (either by being absorbed or else passed on to the customer – or, of course, some combination of the two). Neither will such customers be meeting the costs of the overall deficit in one year – it is the annual costs of the deficit repair charges that is the concern. [Edit 4 December to reference this blog post: some clear factual inaccuracies but, in the context of the WSJ being published by News Corporation, which owns 39% of BSkyB, quite a brave one!]

Nevertheless, we can’t escape the truth that these are costs that should have been present in BT’s regulated cost structures all along: pension deficit charges are a normal business cost and need to be treated as such. Say that Carphone Warehouse or BSkyB (just for the sake of example) ran a defined benefit pension scheme for their employees (crazy example, I know!) and that this was running a deficit: the costs of financing that deficit would be passed on to customers: the money to do so can’t just be magicked up, somehow abstractly from the results of trading activities (even in a paper-based world). Not to pass on the totality of such costs might even be treated as a company trading fraudulently. So, allowing regulated companies to encompass the totality of their pensions costs in their assessed cost structures is a sensible move.

BSkyB has also made serious accusations (see above link to newspaper reports) about having to ‘bail out BT for the mismanagement of its pension fund’. Perhaps, these are even libellous ones. Firstly, the job of managing the pension scheme is not the job of BT but of the trustees of the scheme. BSkyB seems to be over-focusing on ‘aggressive investment policies’ (partly, from a reference to investment policy in the consultation document). Yet, the BTPS investment policy has not been any more aggressive than others: it is a mixed one, designed to maximise investment returns (and therefore focusing, like any other investment manager, on more risky assets) but balanced enough with low risk investments to ensure that pensions can be paid. Ofcom’s consultation document makes it clear that the effect of the investment policy is that returns on assets have ‘consistently outperformed’ its benchmark and are ‘in line’ with a separate independent benchmark. BSkyB needs to think very carefully before making such allegations.

The other part of BSkyB’s accusations was that BT has ‘systematically undercontributed’ to the scheme in the past. There are two major sub-themes here, which also feature in the consultation document:

– BT has taken a pensions holiday from the BTPS in the past (when the legislation on pension schemes – and for fairly good reasons, at the time – sought to prevent companies from over-funding schemes, essentially using them as vehicles for tax dodging). With hindsight, that is a regrettable set of circumstances, although it should be noted that deficit contributions in the past few years have surely wiped out the holiday

– the BTPS has been used to bear the costs of the company’s leaver schemes prior to Newstart. This is to some extent true – although such schemes have not been used for several years, while the Trustees have also required BT to make additional contributions in respect of such costs.

Once again, we have to remember that pensions are long-term investments: an improving economy and growing investment returns will see pensions deficits falling – even to the point of schemes perhaps one day even again being in surplus (when pensions-based costs would clearly fall). (Shurely shome mishtake?) These are abnormal times and basing policy on the impact of such abnormality is, on top of the regrettable short-termism which characterises company policy-making, an unlikely foundation for rationality. At the same time, as Ofcom recognises, BT has already taken steps to reduce the costs of the BTPS by agreeing with Connect and the CWU changes to the scheme’s benefits structure. So, the costs of the deficit are not spiralling out of control and may well fall.

Nevertheless, in the wider scheme of things, particularly were defined benefit schemes still to be the norm, it’s evident that treating the full pension costs of regulated companies may well be seen as one further nail in the DB coffin since, in a regulated environment, this is increasing the consumer-based pressures on companies with such schemes to get rid of them (either partially, as many have already done; or completely, as some are now doing). Should Ofcom decide not to include deficit repair charges in regulated cost structures, that puts pressure on the other regulators to re-think their approach which, in turn, puts pressure on good quality pension schemes in those industries.

Some tough thinking awaits.

* BSkyB lives in Isleworth; Carphone Warehouse in Acton.

Written by Calvin

02/12/2009 at 1:32 pm

BT’s pensions deficit: a little reminder

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BT announced its second quarter and half-year results this morning. Aside of the usual accounting-based shenanigans over whether Q2 profits have gone down by 44% or increased by 2%, much of the press comment has focused on two issues: the state of the deficit in the BT Pension Scheme; and the scope of likely future job cuts.

The £9.4bn deficit in the BTPS that is being reported represents what accountants estimate the deficit would cost under the IAS19 measure. Under IAS19, ‘the cost of providing employee benefits should be recognised in the period in which the benefit is earned by the employee, rather than when it is paid or payable’. This may well be a prudent assumption in financial accounting terms, but it is a rather unrealistic set of assumptions in terms of how pensions are provided which – for example – takes no account of the investment returns which will (hopefully!) be earned in the period between when those benefits are accrued and the point at which they are actually cashed. We should also note that this £9.4bn is a gross figure – net of tax, it comes down to £6.8bn.

The most important figure we need to note in terms of the scale of the actual pensions deficit – the triennial valuation – is still unknown. This was due at the end of December 2008 and is the only figure that counts in pensions terms: it is this that will assess formally the cost of the past deficit and a recovery plan in which this must be made good, as well as setting a contribution rate in respect of future service (which will, in future valuations, be much lower as a result of the changes made to the benefits structure of the BTPS as from 1 April 2009). However, the company, the trustees of the scheme and the Pensions Regulator have been locked in discussions ever since about some of the assumptions on which the valuation will be based. Unfortunately, but inevitably, this has led to speculation not just about the basis of those discussions but also the scale of the deficit. It has been reported, however, that a conclusion to those discussions is ‘unlikely this year’.

Once Connect has further word on what the valuation says, we will be communicating with members.

The Times report of the accounts announcement today also refers to an ‘about to begin’ consultation by Ofcom on whether BT’s pensions costs can be taken into account in setting prices (a story it carries in slightly fuller detail, without quoting anything specific from Ofcom here). A similar consideration featured earlier this year in the Ofcom consultation on Openreach’s cost structure and the regulator then, despite the submission by Connect and the CWU, set its face against Openreach being able to take a share of that deficit in its prices. That is a slightly different issue to one concerning how company-wide deficits feature in the the corporate pricing plans of even regulated companies – but we will be arguing with Ofcom the same point as we argued over Openreach: the deficit has to be owned by someone and represents a part of the costs of any company which must be taken into account in how it sets its prices.

On the issue of job loss, Vodafone and BT seem to be playing a rather unhealthy game of catch-up on cost reductions: Vodafone earlier this week inflated its own prospective cost savings to £2bn for this year and now BT is doing something similar, inflating its target from £1bn to £1.5bn. BT employees will be feeling the pressure of the impact of such announcements, especially in a situation in which the company is being openly vague about the future of its Newstart programme. Again, if we have any word that BT’s continuing job loss programme is to be stepped up, we will be communicating directly with members.

One final observation: the company intends to increase its full-year dividend to shareholders by 5%. Nice to know that the shareholders are being looked after despite what is happening on jobs and pay for BT workers but – aside of that – my observation would be that a company that is looking at increasing its dividend does not generally see itself as a struggling one.

Written by Calvin

12/11/2009 at 1:00 pm

September RPI published

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The September inflation figures have been published by National Statistics: the formal picture is that the Retail Price Index slipped further, to -1.4%, while the Consumer Price Index, the measure used by the Bank of England as a context for its monetary policy, fell to 1.1%.

The largest single factor affecting this month’s figures compared to those of August is the spike in energy prices last year, which saw power suppliers put their prices up in September 2008, while energy bills were this year unchanged between the two months.

Ten of the fourteen groups of items in the consumer basket rose on an annual basis by more than the headline RPI rate, led by leisure services (a year-on-year rise of 4.8%) and household goods (4.5%), but these were heavily outweighed by the 11.2% drop in housing costs and the 7.9% drop in fuel and light.

You can find a useful historic look at inflation, dating back to 1948, here.

The September figures are important ones as they are traditionally used to guide next year’s rises in pensions, both in the state pension and for pensioners of occupational schemes. The basic state pension will rise next April by £2.40 per week, to £97.65, following the government’s promise that the 2010 pension would rise by the higher of RPI or 2.5%. Figures traditionally show that, while the level of inflation differs from group to group as a result of typical spending patterns, it hits pensioners hardest.

A negative RPI in September means that members of occupational schemes – including the hundreds of thousands of pensioners in Sections A and B of the BTPS – are unlikely to see rises in their occupational pensions next April (though they are also unlikely to see them ‘reviewed negatively’ (or cut!) in line with the fall in inflation either).

Written by Calvin

13/10/2009 at 11:48 am

Posted in Economic trends, Pensions

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BT’s pensions deficit

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BT published its first quarter report and accounts yesterday – a set of numbers which certainly seemed to excite the City although I’m not quite sure that it counts as a green shoot. Certainly Livingston was disounting that in his conference call to analysts.

Anyway, the accounts did disclose a doubling of its pensions deficit, to a net figure of £5.8bn (since the gross amount of deficit can be offset against tax), over the last three months. Despite the overall rise in the stock market in this period, which added over £1bn to the assets of the scheme, taking it back above £30bn, changes in the company’s assumptions about rates of return on those investments and about inflation exacerbated the liabilities by a much higher figure.

The deficit as revealed by the accounts has no implications for what the company needs to do in practice about the scheme. The IAS19 measure – which is the basis of accounting for final salary pension schemes – is a snapshot of the state of the scheme from the perspective of the timeframe of the annual accounts; that is, the position were the scheme called upon to pay liabilities within the year. (Incidentally, the role of this measure in exacerbating the public panic on pensions is one factor in the decline of private sector defined benefit provision that seems to have been forgotten about these days, although it’s also true that the City boys and girls yesterday didn’t seem to notice the size of the deficit, or else they discounted it…) By itself, it changes nothing.

In contrast, the real deficit in the scheme is the one revealed by the triennial valuation of the BTPS, which was due at 31 December 2008. This is the one that will force the company to put more money in the scheme (as is likely) and we don’t know what the size of the deficit as revealed by the valuation is going to be: it may be worse than the above figure; it may not. At the annual accounts presentation in May, the company said that it had reached ‘an advanced stage’ in its discussions with The Pensions Regulator over the valuation (that it was having discussions with the Regulator at all is highly unusual and a sign of the interesting times in which we live), but clearly no public progress has been made to shift that ‘advanced’ stage into the ‘final’ one.

The interesting thing about the publication of the accounting deficit figures yesterday is that they reveal a decline in the AA bond rate (which is used to assess rates of investment return into the scheme), from 6.85% in the annual accounts to 6.2% now; and a rise in the inflation rate, which is used to discount the value of liabilities extending into the future, from 2.90% in the annual accounts to 3.25% now. The decline in the AA bond rate was expected (as Robert Peston explains) but the rise in inflation at this point was less so. The measure focuses on RPI which, as we know, is currently heavily negative although the current position is less important than what will happen in the long-term.

BT’s accountants clearly think it is prudent to allow an increase in the inflation rate at this time, compared to what the figure was three months ago, but I wonder whether this is also the view of the Pensions Regulator?

Written by Calvin

31/07/2009 at 9:40 am

Posted in Pensions

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