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I have over 15 years experience of investment generally, although I am a relative newcomer to the pension scene. I also have had an interest in venture capital for several years now, and I am a non-executive director of the Pennine Downing Ethical VCT, which gives me some insight into the workings of the venture capital industry (and I have some industry knowledge of the “green” business sector) I have previously sent you a paper on the links between SRI and your review, which I hope you found interesting. This paper provides a more detailed response to your consultation paper. Note that the most extensive responses are to discussion points VIII on pension law and trustees, and discussion point XVI on benchmarks, but these responses have relevance elsewhere. I take as my starting point that the inquiry is concerned about whether there is excessive caution caused by structural factors in the investment of pension fund assets, to the detriment of both long term returns and the UK economy. While it is difficult to prove I would tend to agree. As an investment banker in the eighties I routinely profited from the conservatism of pension funds – they created arbitrage opportunities for me as they were the last to discover and use new techniques and instruments (usually just as they become less profitable). Much of my work in SRI focuses on this point about whether a failure to take a long term view adversely affects performance, and there is increasing evidence that this is the case. Related to this is the fact that pension funds seem reluctant to consider new ideas and instruments, even at the margin – a lack of “prudent innovation”. Without the sense that such exploration is acceptable and even desirable, funds will always be slow to adopt new ideas. I have taking the liberty of making some specific suggestions that I hope you find useful. Some of the key ones are: Consider identifying and promoting best practice in pension fund investment (so it attention shifts from merely avoiding bad practice) Consider, new more appropriate benchmarks for pension fund investment. Consider more focused and meaningful disclosure and reporting. On the second point I am currently preparing a paper on a new benchmark for the UK which I will forward to you when it is completed. Please feel free to contact me if you wish to discuss any of the points in this document. My Contact details are: Mark Mansley T: 020 7704 9301 2 Martineau Road F: 020 7690 7542 London N5 1NG e: mark@claros.co.uk A couple of observations Before moving on to the specific discussion points I would like make a couple of observations which I hope you will find of interest and will help inform your review. 1: How pension funds lost Ѓ50bn (while being prudent!?) It is not often recognised that UK pension funds collectively lost up to Ѓ50 billion pounds during the nineties through a bad investment strategy. This was collectively to overweight overseas equities heavily towards Asia and underweight the US. As the US outperformed the Asia dramatically during this time, the result underperformance cost the UK pension industry dear. This amount dwarfs the amounts lost in the Maxwell fiasco, yet has attracted hardly any comment, and indeed everyone involved would argue they have acted prudently. Some interesting observation can be made about this: Firstly, this was an active strategy – a market neutral strategy would have used the weights in the World ex UK indices. Yet it became the norm, and resulted in the anomalous position that a fund that wanted merely to have a market weight asset allocation would be seen as standing out from the crowd to a possibly unacceptable degree. Secondly, the losses resulting from this investment strategy were many times larger than the potential risks from taking a more active position in venture capital, or a more positive approach to socially responsible investment. But the attitudes of the pension fund industry to the former was one of almost unquestioning acceptance, whereas the latter ideas are continually treated with scepticism and extreme caution. Finally, and rather ironically for the review, many would argue that this was a long term strategy that went wrong – investment in Asia was justified on the basis of the excellent long term growth of those economy. 2 Ignoring Project Finance. Project finance is an increasingly accepted financial technique for large-scale infrastructure projects in power, transport, health etc. It is being expanded by the Government’s Private Finance Initiative. Typically it consists of long-term projects (15-30 years), with reasonably defined cash flow and strong asset backing. Investment in such projects offers reasonable returns with good income and low risk, with the capital being amortised over the life of the project. Investments are however, usually illiquid and take the form of private (unlisted) equity. Project finance appears to me to be an ideal investment for many pension funds with its long term, low risk nature, particularly for more mature funds. However, with one or two exception (Innisfree have launched a PFI fund with pensions money) the level of understanding of project finance is negligible in the pension industry. A not atypical response is to observe it is private equity and thus to categorise it as venture capital (when it has a completely different risk return profile). If venture capital is struggling for pension funds investment attention, project finance is at an even earlier stage. The fundamental question is: Why is the pension industry so reluctant to consider an investment that is so suitable for them? It points to some major problems within the industry in considering new ideas. Insitutional Investment and Venture Capital (note: do the figures of investment capital include 3i (and some other listed venture capital investment trusts) normally classified as listed companies, but they are really examples of venture capital.) (Discussion point I) Supply Issues. Although my experience of venture capital is sector specific, it is my experience that there is adequate supply, although it could be questioned whether the quality of the deals is enough. (There is also some chicken and egg here – if finance was more prevalent it would doubtless encourage supply.) On the quality of the deals, it is also worth noting that both the British Government and British Industry are I suspect far less good at nurturing small business than either the continent or the US. Support in the UK tends to be limited to talk and soft support – in the US they back nascent technology companies with serious amounts of hard cash for research and companies are often prepared to provide long term contracts and partnerships (linking back to the short term pressures on companies from investors?) (This is of course beyond the immediate scope of the review.) (Discussion point II) Transaction costs. From my own research on this it appears that it is not some much visible transaction costs per se, but “significance” that is the big stumbling block – it is not worth trustees and managers time spending a lot of time discussing an investment for only 1% or 2% of the portfolio. However well such an investment does it is unlikely to have a significant impact on overall performance. With so many other pressures on trustees time it becomes even easier to ignore such marginal decisions. Suggestion: One possible solution would be to encourage the formation of a “fund of funds”, which would essentially provide a collective decision making capacity, if there was adequate industry support. Liquidity: I feel there may be an excessive obsession with liquidity of assets among pension funds (whether for the supposed day when crisis hits and it is necessary to sell, or so mandates can be switched). This leads to a preference for large listed companies and bond issues, and militates against investment in smaller companies, venture capital and other schemes. Given, on the one hand, that liquidity can be rather illusory (and quoted prices are not always that meaningful) if a pension fund becomes a major forced seller, and on the other, that in ordinary circumstances the need for liquidity in investment is relatively marginal (i.e. only 10% in reasonably tradable assets would probably cover most eventualities), there is considerable scope for changing attitudes to liquidity. There is arguable no reason why pension funds could not have substantial investments in relative illiquid assets that produce good income over the long term (e.g. project finance, unlisted mature companies etc) Suggestion: The government, in conjunction with industry bodies could seek to establish best practice and issue guidance notes, with the point of emphasising that a reasonably large proportion of unquoted investments is acceptable (say up to 25%) as long as return, risk and income are satisfactory. Suggestion: Going beyond this, if the government is keen to encourage investment in illiquid assets it could provide some form of liquidity guarantee – i.e. a promise that if the institution needed to realise liquidity rapidly as a result of some crisis it would offer to buy the assets for cash (could see this as being a “buyer of last resort”). Such a guarantee is unlikely to be expensive to provide as the guarantee only costs money if there is firstly an event which creates the need for liquidity and then if the realisable value of the assets is less that the price paid. (Note: such a guarantee could be such an important way of encourage insurance companies to invest venture capital, where liquidity rules are stricter. Such guarantees could result in illiquid assets being essentially treated the same as liquid assets.) (Discussion point III) Partly it is the usual financial herd instinct, partly it is down to genuine reasons – changes in technology, legislation etc., create opportunities in particular sectors which become the focus for business opportunities (e.g. MBOs were popularly partly because of the focus on restructuring of large corporations in the nineties). However, in addition it partly reflects the relatively small size of the UK VC market which as a result can firstly be rather clubby, and secondly has only limited resources so cannot become experts in all fields – transaction costs are definitely an issue here, particularly in favouring larger deals. Suggestion – Consider joint actions with the Regional Development Agencies, the DTI and others on the issue of transaction costs in particularly in less popular areas – start ups, non-IT technology businesses etc. Pension funds - Objectives (Discussion point IV) Reasonable accurate. It is not clear to me that the employer are that active in expressing a view on the risk or investment profile of a fund – some may even prefer a more aggressive investment strategy. There is definitely scope to get the sponsor to taking a more active role in looking at the investment profile of the fund, and to encourage innovation. This is something I have looked at with my work on SRI where many sponsors are more aware of the business importance of social and environmental issues, so can help pension funds understand the best strategy. One effect of the Pension fund Act 1995 has been to perhaps over-separate sponsor and the pension fund (e.g. the limitations on the ability of the sponsor to underwrite the liability of trustees) Suggestion: encourage business leaders to take a more active role in the investment of their company’s pension fund, including encouraging prudent innovation, perhaps through a high level forum. Look at mechanisms by which employers can provide some reassurance to trustees, reducing the risks they face. (In the SRI area I have advocated the use of a letter which states the policy on social and environmental matters reflect prudent business practice – which would provide substantial support to trustees in the case of a lawsuit). (Discussion point V) Possibly, DC schemes tend to be even more narrow in their investment strategy than DB schemes, and even more focused on short term returns. The potential to offer members choice could help overcome this, but in practice the choices tend to be very limited (i.e. between different types of near benchmark funds, rather than offering more innovatively managed funds.) Pension Fund trustees (Discussion point VII) Yes (Discussion point VIII) In my view trust law lies behind the conservatism of most pension funds. Trustees are in an appalling position – unlimited downside liability and virtually no upside. Not surprisingly this results in them taking an extremely cautious approach, and very reluctant to consider doing anything different. (A senior pension lawyer has commented to me that his real advice to anyone considering becoming a pension fund trustee would be simply: “don’t”.) The obvious approach to minimise risk is to ensure that you don’t stand out from the crowd, which results in extreme inertia. When this is combined with the relatively modest amount of time that trustees have to devote to their duties and their lack of inexperience, it is no surprise that the pension fund trustees veer on the side of excessive caution. The fundamental constraints that the trust law creates are then further amplified by the vast amount of additional legislation specific to pension funds – notably the Pension Act 1995 and its reams of attendant regulation and guidance notes – compounded by case law, European law, tax law, etc. While the Maxwell fiasco created a desire to avoid the worst practice, the resultant system consists of belts and braces galore – the fundamental provision of trust law is now backed up by the requirement to seek professional advice, reinforced by the creation of OPRA, buttressed by some disclosure requirements, supplemented by specific rules on MFR and on investment in the sponsor, expanded by the requirement to have member trustees etc. The result is to further enhance the case for extreme caution by pension funds – firstly because that is the thrust of much of the law, and secondly because after worrying about compliance in all its various forms, there is hardly time to consider innovation or originality. Suggestion: Your review could, and I believe, should, consider a radical review of pension law, moving perhaps from a trustee to basis to one where pension funds were more similar to corporate bodies (e.g. company limited by guarantee), and where the duties and liabilities of pension fund trustees resemble more closely that of company directors. Similarly pension funds could benefit from the accounting and reporting techniques used by corporations. Such a move would be major change and needs substantial thought before undertaking, but without it I suspect that then tendency to excessive caution will always remain, and that other measures will remain marginally. In undertaking such a major review, however, it should also be the goal to reduce the overall regulatory burden on pension funds, through removing unnecessary requirements (e.g. is OPRA really necessary?). A number of other options are possible as an alternative (or addition) to such a fundamental change. Suggestion: a broader perspective. Firstly it might be worth looking at the way the law (or its current interpretation) requires pension fund trustees to have a very narrow interpretation of what they should consider when considering investment strategy. Trustees are very reluctant to consider the broader role of their pension fund in society, even where it may have an indirect impact on members. (Members would undoubtedly prefer their fund to be invested in a way that helps safeguard a healthy domestic economic, social stability and an environment they can enjoy.) This caution arises from the Megarry Judgement in the Scargill case – where such issues were given very short shrift. This has resulting in trustees interpreting their responsibilities in very narrow, short term financial sense. Even the progress that has been made on SRI, where it is now recognised as acceptable for pension funds to consider such issues, has largely been done on the grounds that they can deliver benefits to members (financial or otherwise) rather than the fact that they generally contribute to a “better world”. There is some merit in revisiting the point, either through the statute book or through a test case - the Megarry judgment was probably right in its own terms because the actions at the heart of the dispute were extreme and being advocated regardless of their financial merit, but the impact has been to discourage any broader considerations even at the margin where they make no difference to returns. What is need is a clear statement, by a court or through law, that, while financial interests remain paramount, pension funds can, and indeed should, be mindful of the broader impact of investment strategy on society as a whole, should act a responsible citizens and should consider any financial consequences that might arise in the long term. Suggestion: best practice: There is potential to use the idea of best practice to help break the deadlock. By identifying and promoting best practice in pension fund investments, trustees will have something to compare themselves with formally. Encouraging a focus on achieving best practice, rather than merely avoiding worse practice could have a major impact. It would also be very useful in reducing trustees fear of liability. Funds could even be asked to report on where they have deviated from best practice and why. Using best practice will first of course involve identifying what is best practice – which involve extensive discussion, and ensuring that it does not just end up being the average. Suggestion: Support “Prudent Innovation”. However, one key element should be to formally recognise the role of “prudent innovation” – the idea that pension funds feel encourage to explore new investment ideas and concepts but with a relatively small amount of the fund (e.g. up to 10%). Some form of ruling (whether regulation, statute book or even case law) should be used to give formal backing to the idea of prudent innovation including some guidelines on what is reasonable and acceptable. Suggestion: There may be scope to enhance the role of the internal pension manager. Often these people are the driving force for change in the pension fund and responsible for change, with trustees acting as an inhibiting force. It might be worth exploring whether it is worth strengthening the role of the pension manager, particularly where professionally qualified (e.g. APMI) – this could include counting a professional managers as a suitable qualified on investment matters under the 95 Act, which would also have the effect of reducing the role of consultants etc. Investment Consultants (Discussion point IX) Probably the biggest incentive for investment consultants is to provide reassurance for trustees – that rather than the actual quality of the advice is probably more important. This leads to an emphasis on showing what everyone else is doing, both formally (you are near the median) and informally (lots of our clients are doing this). (Discussion point X) Probably fairly neutral in terms of this review. Certainly at present it is giving rise to more core-satellite strategies (often with the core indexed), but I am not sure what broader impact this has. On the one hand could encourage more choice and selection, and avoid the problem of balanced managers only investing in their own areas of competence (which may exclude VC) , but on the other hand as that choice is now in the hands of trustees and consultants they may be more conservative, and there could be more pressure on the satellite mandates to generate results in the short term. (Discussion point XI) Possibly. Certainly there is a limited choice and it is fairly difficult to enter the market (the point above about reassurance is a significant barrier) Suggestion: Consider requiring a formal separation of investment consultants and other pensions advisors or at least making it best practice to separate the two. Fund Managers (Discussion point XII) Broadly, yes. (Discussion point XIII) Because fund managers can’t deliver?! Seriously, fund managers clearly prefer a guaranteed income stream, and are unlikely to prefer success fees. Without widespread pressure to encourage change it is not surprising they prefer the status quo. For pension fund trustees fees are (rightly) only a fairly minor consideration. (Discussion point XIV) Risk Management models have undoubtedly increased discipline in the fund management industry, and made performance more attributable. However, they have reduced diversity in investment strategies (through identifying risk more clearly and thus making it harder to justify). I also have some fundamental doubts about taking quantitative risk management too far. It is based on retrospective analysis of data and focus on relatively short time periods. Underlying the analysis are certain mathematical assumptions which may not be valid (normal distribution of returns), particularly in the long term. No account is taken of prospective risks which can be identified but have not yet impacted on returns (many environmental factors fall into this area, but also so does the underlying concern behind your review about whether UK institutional investment is most effective at creating long term wealth.) This goes back to the issue of taking a broader perspective above. (Discussion point XV) Economies of scale, combined with the effect of industry wide recommendation by consultants. Lack of competition is potentially becoming an issue. A key point here is the financial regulatory environment in the UK deters competition and innovation through bureaucracy and cost. Measurement and Benchmarking (Discussion point XVI). Broadly I would agree with the assessment here. On the point of liquidity, I am sure that there are ways round the problem with suitable clauses in the mandates. Where investments are being made in instruments such as venture capital funds these should start to repay over a reasonable time frame, giving funds the opportunity to reinvest elsewhere. I feel you under-emphasise a key point on benchmarking – are the current benchmarks appropriate? Not just in a short term versus long term but as a basic starting point. Benchmarking is inevitable and desirable. However, it is important that the benchmarks chosen by institutional investors reflect are genuinely in their best long-term interests, determined broadly. Furthermore, the impacts of the chosen benchmarks can be large and profound on the economy as a whole – dictating default ownership patterns and investment flows – and should also work in the best interest of the UK generally. I am not sure this is the case at present – benchmarks seem to be chosen for historic reasons as much as anything else. Suggestion: The Review should provide some specific guidance on appropriate benchmarks: I would suggest strongly recommended avoiding the use of median / peer group benchmarks as these tend to create clustering. As an alternative, it might be possible to develop some best practice benchmarks – either based on the performance of certain funds selected as following best practice, or on a notional best practice portfolio as agreed by experts. Within the key UK equities market, The All Share Index is becoming increasingly unsuitable – too concentrated, including quasi foreign companies etc. As a result I strongly recommend considering new equity benchmarks. My own suggestion is a “UK All Comers” index, based on all major companies with significant UK operations, weighted according to the size of the UK proportion to the whole company. An following paper will cover this in more detail. (Discussion point XVII) Firstly, I feel your suggested time periods – three to five years – is actually longer than the many fund managers feel is the real time frame – many would say you have three bad quarters and you are in a lot of trouble. Secondly this time frame problem is a fundamental one – one the hand the only valid time-frame is a long term one, but if the fund manager is no good, trustees don’t want to hold on to him longer than necessary. No easy answers to this but it might be worth undertaking some research on how one can distinguish bad performance from unlucky performance, which could probably be done using mathematical modelling and game theory (indeed some may already exist.) (For example, a fund manager with a genuine underlying outperformance capability of 1% per annum but with a tracking error of 5% would still have a 33% chance of underperforming over 5 years.) One key factor is that active fund managers probably overstate their outperformance objectives for a given level of risk, partly because pension funds have unrealistically expectations in this area. Suggestion: There is probably some merit in exploring longer term management contracts which can only be cancelled in predefined cases (e.g. of fairly severe underperformance or where fund manager breaks the terms of the mandate). The underperformance rules could be objectively based on the research above. The mandate could also be combined with a form of success fee. (Against this locking up funds in major contracts will again make it harder for new entrants). Transparency and accountability (Discussion point XVIII) I strongly favour increased accountability, as it help ensures prudence and encourages best practice. At present I believe there is too little discussion both among the public at large and among the beneficiaries (see my observation at the start). Key factors here is that the SIP is too vague and too variable, and that reporting can often be too extensive and confuse members. Reporting also needs to be effective and concise.. Suggestion: Look making pension funds explicitly report on key matters such as long term investment strategy and venture capital (similar to the SRI disclosure regulation). This could include disclosure of variation from best practice standard if one is developed. Also consider how reporting can be improved – is there a role for more standardisation (or a reporting best practice model), and whether all information should be sent to members, or merely a summary with key points with the rest available on request. Suggestion: There is also scope to encourage that third parties pay more attention to venture capital and other forms of investment when they report and survey the pension industry. For example, the CAPS survey results summary mergers venture capital into “other”, emphasising just how ignorable it is. (Discussion point XIX) Decision making quality should not suffer as a result – indeed the opposite is more likely to be true. Regulatory and Legal Issues (Discussion Point XXI) The MFR. My experience is that the incentive effect of the MFR is substantial and that it helps add to the overall conservatism of pension investment. It increases the focus on performance against the benchmark. Indeed it helps to eliminate any discussion about what benchmark is most relevant and applicable – which indeed is a discussion that should be more active. (see my comments on benchmarks and my alternative index proposals). The key point here is deciding what is low-risk – it is questionable that the UK equities are any lower risk than, say international equities or even venture capital in absolute terms (especially in the most relevant sense – that a particular level of value may not be achieved in long term). However, the workings of the MFR is such that certain portfolios (i.e. UK equity index has no risk) whereas any deviation from it is seen as creating additional risk. (This debate has become very relevant in Socially Responsible Investment circles, where SRI portfolios are not more risky (and may be less risky) that the market in absolute terms, but are inherently more risky relative to the index (because they are different)). (Discussion Point XXIII) Valuation and Liquidity I suspect the rules on valuation of assets may have relevance, although I am not that familiar with them. In particular, it may result increase the focus on quoted investment over unquoted investments (although of course the price of investments is somewhat illusory in the situation where major pension fund (or funds) becomes a major forced seller). This point is related to discussion point ii on liquidity. Local Authority Schemes (Discussion Point XXIV) Many of the points also apply to local authority schemes. However, local authority schemes have general been more progressive – in investment in venture capital, in corporate governance, in SRI etc. This is firstly because of political nature of local authority scheme trustees (i.e. local councillors) - so they have a greater interest in taking a more activist stance (they may feel some personal or political benefit from these actions), and secondly because of the much higher priority and greater professionalism attached to the pension scheme by the local authority administration – often it is the direct responsibility of the Director of finance or Treasurer, and they will often have a high level professional qualification (e.g. CIPFA) Mark Mansley  My rough estimate based on asset allocations to Asian and US equities and their returns (using CAPS data) Comments on Myners Review by Claros Consulting July 2000  PAGE 9 `jkxF_?š›Yuйгіd Œ v""B#L#.'9'\(h(ž+Г+2.<. /$/8/62A2N4a4г5щ5ў5667=B= A,AMHgHK:KM M?OVOjOНPаP!S5SвSнSuTƒT˜TЈTОTVVхYљY[/[D[t_€_єb cBgMgi5iLi$j(j§j kmїђььъуъьђђпђппђъьђпђьђђпппппьђђђпьђђђђьђъђпьђнп656 j0JU5 5OJQJOJQJ5CJOJQJWK`jkyzќ§opa b з ^ Ѕ х ц klЦЧпџ"F_§љљ§§§§§§§§§§§єєє§§§§§§§§§§§ & FЄxK`jkyzќ§opa b з ^ Ѕ х ц klЦЧпџ"F_?ŽоXYuжзивгc d u"v"A#B#-'.'[(\(+ž+1.2./ /$/5262M4N4в5г5щ566@9A96=7=Ѓ@Є@ AGHLHMHKKMM>O?OVOМPНP Sќі№ээчххх           Z?ŽоXYuжзивгc d u"v"A#B#-'.'[(\(§яяооо§яя§§§§§§§§§§§§§§§§ & F$d%d&d'd $d%d&d'd\(+ž+1.2./ /$/5262M4N4в5г5щ566@9A96=7=Ѓ@Є@ ALHMHKKMM§§§§§§§§§§§§§§§§§§§§§§§§§§§§§M>O?OVOМPНP S!SбSвStTuTƒTЈTVVфYхY[[/[Ї\Ј\R]s_t_Ь_H`0a§§§§§§§§§§§§§§§§§§§§§§§§§§јѓ & F & F S!SбSвStTuTƒTЈTVVфYхY[[/[Ї\Ј\R]s_t_Ь_H`0aѓbєbwfAgBgii5iќj§jmm3n5nГnДnаnœpqsrsЃs>u?u@uXuZx[x\x]xjxkxзxиxyyyyy yќљієєєђяђє     =0aѓbєbwfAgBgii5iќj§jmm3n5nГnДnаnœpqsrsЃs>u?u@uXuZx[x\xњјјјјјјјјјјјјјјјјјјјјјјјјјјј & Fmm5nKnДnаn№nrsЂs@uXupukxlxиxyyyyyyyyy yќїёїїёїътлЮХЮКЮл0JCJOJQJmH0JCJOJQJj0JCJOJQJU CJOJQJ5CJOJQJ j0JU 5OJQJOJQJ56\x]xjxkxзxиxyyyyy y§§§ћ§ѕ§№§§§$d$&d # 0&P А‚. 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