Tag Archives: mortality

Tax reform provides incentive to accelerate pension contributions

The end of 2017 saw the passage of significant tax reform in Congress. With this tax reform, the corporate tax rate has dropped from 35% to 21%, generating quite a bit of attention due to the significant savings that will result for corporations. One relatively unpublicized result has been the additional funding of cash contributions to corporate defined benefit plans.

While contributions made for the 2018 plan year will generally be deducted at the new lower corporate tax rate of 21%, contributions for the 2017 plan year will generally be deducted at the higher rate of 35%. For many corporations with underfunded pension plans, contributing additional dollars or accelerating already planned contributions will generate a net tax savings because underfunded plans are expected to eventually require additional contributions.

More and more, the plan sponsors are issuing corporate debt to make additional pension contributions. For example, General Electric recently announced that it was making a discretionary contribution of $6 billion into its pension plan funded through debt.

In addition to recent tax reform, here are three other reasons we are seeing this trend on the rise:

1. Skyrocketing Pension Benefit Guaranty Corporation (PBGC) premiums. The variable rate premium that corporations pay on underfunded liabilities has increased from 3.4% of the underfunding in 2017 to 3.8% in 2018 (and 4.2% in 2019, as listed in the PBGC website). Any contribution in 2018 to the pension plan immediately reduces the PBGC premium by 3.8% in 2018 (and more in future years). Additionally, that money would then be invested and anticipated to grow with the plan’s expected return (say 6.25%). This leads to an effective return on capital of 10.29% in 2018 (and 10.71% in 2019), and higher returns are anticipated in future years.
2. Updated mortality will drive PBGC liabilities higher by approximately 4%, leading to significant increases in the variable rate contribution.
3. Corporate interest rates remain low and corporations are able to borrow at relatively low costs.

For the purpose of example, let’s look at a theoretical additional contribution of $10 million into an underfunded pension plan. This additional contribution would:

• Reduce fees paid to the PBGC by $380,000 in 2018 (and $420,000 in 2019, and growing in following years)
• Be invested in the trust, and therefore would be anticipated to grow by a company’s expected return on assets in 2018 (likely 5% to 7%, which translates to $500,000 to $700,000 on a full-year basis)
• Reduce the Financial Accounting Standards Board (FASB) accounting expense in 2018 and beyond (by an amount similar to investments in the trust, depending on timing)—to the extent these contributions were anticipated at the beginning of the fiscal year
• Be tax-deductible at the 2017 corporate tax rates because any contribution before September 15, 2018, can count as a 2017 plan year contribution for calendar-year plans

However, there are some limitations:

• While plans that are fully funded on a PBGC basis will not see additional PBGC savings, they will see the additional tax and expense savings as outlined above
• Because of the structure of the PBGC variable rate premium, additional contributions to plans at the PBGC variable premium cap (due to head count) may not share the PBGC advantages, but will see the additional tax and expense savings as outlined above

With tax reform now in place, many corporations are poised to take advantage of opportunities to improve the financial status of their defined benefit retirement plans. Acting sooner rather than later on this opportunity will enable them to stabilize and move their plans more firmly into the black.

Plan-specific substitute mortality tables

In October 2017, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations prescribing new mortality tables that apply to single-employer defined benefit pension plans for the purpose of calculating the actuarial liabilities for minimum funding requirements, benefit restrictions, and Pension Benefit Guaranty Corporation (PBGC) variable-rate premiums. As with the prior regulations, the new regulations give plan sponsors the option to use either the standard mortality tables developed by the IRS, or to develop plan-specific mortality tables.

The new regulations significantly revised the rules regarding plan-specific substitute mortality tables. Under the prior rules, a plan was required to have fully credible mortality experience in order to use substitute mortality tables. The new rules allow for the use of substitute mortality tables for plans with smaller populations that do not have fully credible mortality experience. As a result, Treasury and the IRS expect that significantly more plan sponsors will request approval to use substitute mortality tables.

Using substitute mortality tables should theoretically improve the fit between expected and actual mortality rates, thereby producing smaller experience gains and losses over time. In addition, for plans employing a workforce that exhibits heavier mortality than the standard tables, using substitute mortality tables could potentially lower both minimum required contributions and PBGC variable-rate premiums.

For these reasons, plan sponsors may want to consider the use of substitute mortality tables. A written request must be submitted by the plan sponsor at least seven months before the first day of the first plan year for which the substitute mortality tables are to apply.

Note that the regulations do not allow plan sponsors to use plan-specific tables for determining minimum lump-sum values; standard IRS tables continue to be used for this purpose.

Lack of guidance may extend “window” for lump-sum distributions

The Internal Revenue Service (IRS) has not issued the anticipated guidance pension plan mortality tables. A recent Bloomberg BNA article quotes Milliman’s Zorast Wadia discussing what plan sponsors must consider, or reconsider, if the IRS does not issue guidance in the coming months.

“The longer we go into 2016 without seeing the IRS issue guidance on new mortality tables,” the less likely such guidance will be issued this year and in place for plans to follow before 2018, said Zorast Wadia, a principal and consulting actuary in the benefits consulting firm Milliman’s New York office… sponsors may want to begin monitoring interest rates to determine the optimal time to offer lump-sum distributions, Wadia said.

Until recently, many plan sponsors and their advisers have been anticipating that these new mortality tables would be required for plans in 2017. The tables are expected to incorporate longer life expectancies and thus make it more expensive for sponsors to offer lump-sum payouts to participants. A delay in the required use of the tables could affect a sponsor’s decision on whether to offer a lump-sum window—a temporary opportunity to take benefits in that form—in 2016.

Wadia said the IRS must also decide whether its new guidance will incorporate the original base tables issued by the Society of Actuaries [SOA] in 2014 with their revised projection scales issued in 2015 or some other basis.

In a 2015 Benefits Law Journal article, Zorast offered perspective on how implementation of the new SOA mortality tables would reduce the accounting gains that are one of the key economic benefits associated with lump-sum distributions. Therefore, if the IRS does not issue guidance concerning mortality tables this year, plan sponsors may have an extended window to consider the potential benefits of offering lump-sum distributions. Any lump-sum offering would of course require a strong communication and education effort to ensure that plan participants are well equipped to make the important retirement decision that lies ahead.

To read the article, click here.

Managing mortality

How does volatility in future mortality assumptions affect the valuation of life contingent liabilities?

That’s the question Stewart Silverman, a principal and consulting actuary in the New York office of Milliman, sets out to answer in “Risk Factors: Managing Mortality Risk.”

Life insurers have been focusing on economic factors, and rightly so given the state of the global economy. But, as Silverman points out, this focus “may have caused many insurers to lose sight of the emerging mortality and longevity risks on their books.”

In the future, however, that risk is likely to grow—people are living longer, leading better lives, and enjoying the benefits of technological innovation in healthcare. Insurers would be well advised to prepare for its influence.

After reviewing the roots of volatility—inappropriate assumptions and difficulty in predicting improvements in mortality brought on by improvements in technology and lifestyle changes—he focuses on how the stochastic analysis that insurers now use to understand asset risk offers similar potential for managing mortality and longevity risks.

More important than the simple fact that life span is increasing, however, is “the fact that the huge strides in longevity over the past 50 years occurred in fits and starts.”

It’s the uneven nature of the improvement in longevity that poses the greatest threat to cash-flow patterns for insurers and financial servicers.