Thank you for inviting me. I'm grateful for the opportunity to be here today.
I would first like to emphasize that I am here as an independent analyst who is very concerned about the current pension crisis. The views and opinions expressed today are solely mine and do not represent those of my current employer or any other organization.
Let me begin with a brief introduction of my background. I was a senior investment analyst to two of the largest public pension funds in Canada, the Caisse de dépôt et placement du Québec and the Public Sector Pension Investment Board, PSP Investments. My experience allowed me to gain valuable knowledge across traditional and alternative investments, such as stocks, bonds, hedge funds, private equity, and commodities.
In 2007, I completed a detailed report for the Treasury Board Secretariat of Canada on the governance of the public service pension plan. This report was an independent review of the plan's governance structure to address some concerns raised by the Office of the Auditor General of Canada.
Let me now get to the matter at hand. Last year was a particularly difficult one for global pension funds, as very few funds escaped the stock market rout. The OECD weighted average ratio of private pension assets to the area's GDP reached 110% in 2007. By October 2008, the total OECD private pension assets were down to about $23 trillion U.S., or about 90% of the OECD's GDP.
The impact of the crisis on investment returns has been greatest among pension funds in countries where equities represent over one-third of total assets invested, with Ireland the worst hit, as it was the most exposed to equities, at 66% of total assets on average, followed by the United States, the United Kingdom, and Australia.
For their part, Canadian pension funds suffered the steepest decline on record, with an average loss of 15.9%, according to RBC Dexia Universe. The Office of the Superintendent of Financial Institutions released the results of its latest solvency testing of federally regulated private pension plans. The results show that the average estimated solvency ratio of federally regulated defined private pension plans at December 31, 2008, was 0.85, a decrease from 0.98, as reported in June 2008.
The financial crisis exposed some serious governance gaps among Canadian private and public pension funds. I will now outline some of the more important governance gaps and make some recommendations on how we can address them.
By “governance”, I am referring to the system of structures and processes implemented to ensure both the compliance with laws and the effective and efficient administration of the pension plan and fund. The six key governance areas in a pension plan are oversight, compliance with legislation, plan funding, asset management, benefit administration, and communication. Given the time constraints, I will focus on three of these key areas: oversight, asset management, and communication.
Pension oversight has always been important, but perhaps never more so than today. Several public and private pension plans are in financial trouble, the regulatory environment is rapidly changing, and market volatility is constant. At the large Canadian public pension plans, pension oversight is the responsibility of the plan sponsor, who nominates an independent board of directors to oversee all activities of the pension fund. The integrity of the nomination process varies, but the intent is to keep political interference out of the key investment decisions by public pension funds.
The cornerstone of pension oversight is risk management, defined in the broadest sense to take into account investment, operational, legal, and fraud risks. The board of directors oversees the investment activities of internal and external investment managers, and it must make sure controls are in place to mitigate all these risks. In order to do this, the board of directors needs to have the requisite knowledge on all these risks, as such risks can expose a fund to serious material losses. Importantly, the board of directors has a fiduciary responsibility to ensure activities are being conducted in the best interests of the key stakeholders.
The failure of diversification strategy in 2008 highlighted the consequences of incomplete or poor oversight. The significant losses suffered at the large Canadian defined benefit plans are the consequences of poor risk controls and compensation packages that reward speculation or performance based on bogus benchmarks. By shifting assets out of safe government bonds, first into equities and then into alternative investments like hedge funds, private equity, real estate, commodities, and other risky investments, pension funds have contributed to systemic risk of the global financial system. This process is what I have dubbed as the global pension Ponzi scheme, because pension funds were investing billions into alternative investments, ignoring the securitization bubble, and without due consideration of how their collective actions are affecting the soundness of the global financial system.
Pension funds claim that the shift into alternative investments was done for diversification purposes, to smooth overall returns, and to deliver absolute returns. However, there was another reason behind this shift to alternative investments: it allowed senior executives at pension funds to game their policy benchmarks so they could collect huge bonuses, claiming they are adding added value to overall returns. This is of critical importance, because such executives have clear fiduciary responsibilities, and that is to their plan sponsors and beneficiaries. The reality is that senior executives are able to reap huge bonuses because they're beating bogus benchmarks that do not reflect the risks of the underlying investments. Bonuses are based on, and awarded annually on, achievement versus benchmark. However, these bonuses are never clawed back when in subsequent years these investments fall well short of expectations.
Most of the abuses in benchmarks are concentrated in private markets like private equity and real estate, but similar abuses are also present in other alternative investments, like hedge funds. Illiquid asset classes are typically valued infrequently by external and in some cases internal auditors. With few exceptions, the benchmarks used to evaluate the performance of these asset classes do not reflect the risk of the underlying investments. For example, leverage is commonly used to boost the returns of illiquid assets like private equity, real estate, and infrastructure, yet the benchmarks used to compensate senior executives of public pension funds do not reflect these risks.
Benchmark abuse has also occurred in public markets. The case of non-bank asset-backed commercial paper, ABCP, was an example of how some pension funds invested in assets that allowed them to handily beat performance benchmarks in their cash reserves, ignoring important liquidity risks that arise between the ABCP conduit's assets and liabilities. Hedge fund benchmarks that do not take into account liquidity risk or leverage of the underlying strategies are another example of abuses occurring at public pension funds.