The challenges facing DB trustees

  • |
  • 34 mins 08 secs

Learning: Structured

Tutors:

  • Bob Campion, Senior Portfolio Manager, Charles Stanley Fiduciary Management
  • Chris Halewood, Trustee Director, 2020 Trustees
  • Sarah Marshall, Trustee, Pi Pension Trustees

Learning outcomes:

  1. The impact of regulation on professional DB trustees investment approach
  2. How to keep on top of regulator and knowledge requirements
  3. How to think about the long term and short term frameworks for funding schemes
Channel: Retirement
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Hello and welcome to this academia learning unit on the investment and regulatory challenges facing professional trustees in the defined pension space. Before we meet our panel, let's run through today's learning objectives. Firstly, the impact of regulation, on professional DB trustees investment approach. Secondly, how to keep on top of regulatory and knowledge requirements. And thirdly, how to think about the long term and short term frameworks for funding schemes. We'll discuss these topics. I'm joined in the studio by bob Campion. He's senior portfolio manager at Charles Stanley, fiduciary management, sarah marshall trustee at pI pension trustees and chris Halewood trustee director at 2020 trustees bob campaign. We're looking at DB trustees, particularly around regulation and long term funding. So, to start this off you charleston, we've done a lot of research around this. So, could you tell us a little bit about what that research consisted of? Yes, sure. Thanks, Mark. So we interviewed a number of professional trustees, 55 Professional trustees, we went out and spoke to to get their understanding of how they felt risk had changed over the last few years. Their attitude towards risk amongst the defined benefit, pension schemes that they're involved with, but also to understand how they feel about regulation, generally about new regulations coming in, like long term funding targets, and also the attitude towards environmental, social and governance investing as well. So it's quite wide ranging questionnaire. And really it's because when we're talking to our clients, many of whom are professional trustees on, on all all our schemes were getting quite a wide ranging views from them about their attitude towards different elements of this. And we really wanted to understand what they wanted from the industry and where their mind was going in terms of what they expected to happen next. Well, we've got a couple of professional trustees with us. Let's let's bring them in Sarah Marsh, could you tell us a little bit about your role at pi pension trustees particularly, what's the size of scheme that you're typically involved with? So our schemes vary quite considerably in size for, for the trusty side and particularly my schemes, I've got quite a few who are under about 20 million. So the very small schemes and I've got one or two that sort of 100 million size. One of the beauties of pious that we do secretarial services for the massive schemes, so, so we do draw on their experiences for our, our trusty work, but generally it's the smaller pension schemes and they're the ones that That don't have the broader knowledge and the wider trustee boards or that certainly, and also, certainly the funds to necessarily looking to get advisers on everything. Thank you for that Chris Howard? Tell us a little bit about the type of scheme you're involved with at 2020 trustees. Yes, sure. Thanks. Mark 2020 trustees, we've got a very broad range of pension schemes that we look after, his professional trustees defined benefit pension schemes ranging from just a couple of million pounds right the way up to multiple billions. My particular schemes that I specialize in tend to be at the smaller end of the market, so similar to serra around maybe 100 million below. I do have one or two, a little bit above that, but predominantly defined benefit schemes with a couple of defined contribution schemes. So very much involved in the particular topics that we're here to talk about today. Well, I wanted to pick out one of the statistics from this Bob. Get your thoughts on this. So that research did you? One of the stats that came off that really struck me as really significant is 78% of those that you spoke to think regulation is stifling their investment approach. Did that surprise you? Well, not entirely. I mean, I think we all know how much investment and every element of running a defined benefit pension scheme has been changed by regulation in the last 10 or 15 years. That does put severe constraints on trustees ability to take risk for good reason. I mean, there's lots of sensible reasons why any trustee would rather have the sponsoring employer contributing funds to the pension scheme risk free effectively from their perspective, than taking risk with the investments in order to grow the parts in order to have enough money to pay for their future pensioners. But I think it's also the case that in almost all scenarios that there's a balance between those two things between the company's happiness and willingness to fund the scheme with their own funds, but recognizing that actually they want the assets to work hard to, to make the most out of the contributions they're making. So it's really a question of to what extent trustees feel they can actually genuinely take as much risk with those investments that they and as they and the company would like to. And part of that is understanding to what extent they're investing for the long term and how long that time horizon really is because for some clothes, for some pension schemes, it's not, it's not perhaps as long as they might think, but there are also other good reasons why taking too much risk for a company that can't afford to pay any shortfall if things go wrong is not the right decision. So it is a complicated area and I certainly think that it's been heavily regulated in the last decade or so. And Sarah you mentioned earlier that you were involved really with a lot of much smaller schemes, DB schemes, what particular influence to size have on this issue. It fundamentally comes down to budget and the energy that the employer is able to put on on, on matters. So with a smaller scheme, you, you can't get the advice that you might otherwise be able to get or you have to rely on on taking a broader view of things or if you're lucky enough to have a professional trustee, then they can draw on their their experience from other schemes. But also, there's not the, the kind of backing from the company, it's a smaller company. So you can't necessarily take that longer term view that you might take with um really big schemes. One of my schemes, for example, you would say it's a scheme with a company attached rather than a company with a scheme attached. So you have to look at it very differently in terms of those risks and that balance of risk. And where do you draw the line? It might be that we think the pension scheme will run for 20 years. But what happens if the company goes bust? And equally sadly, on one of my schemes we've seen because of the triennial valuation process where you take this snapshot every three years and you're expected to make decisions off the back of that, then if you have a bad couple of years for all the right reasons, it reflects very badly and you have to report that to the regulator and then the company has to be making up that deficit. Whereas it could be in the next 10 years that The position and market circumstances realign and what you were doing 10 years ago has worked over those 20 years. But because you're doing those three yearly checks it doesn't necessarily work along the way. So whilst a long term view is important, the regulatory constraint of those three years sometimes catches you out. Thank you chris how much confidence can you have as a professional trustee when you go in front of the regulator? I mean, is there a dangerous self censoring or do you think I put all of this together properly? I can argue my case. I think this is the right thing for us to do. And I think that's actually what's quite interesting in terms of the output from the research. I personally was a little bit surprised, actually, by the significant number of trustees that felt that regulation was stifling their sort of investment process and their investment decisions, mainly because your investment process and decision making is either right or wrong for that particular scheme. And if the regulator wants to talk to you about that, and it doesn't necessarily fit into their box? I think you should have the courage of your convictions to have that conversation with the regulator to say why it's appropriate for that particular scheme. There could be certain nuances within the scheme that make that investment strategy right? For that particular scheme, where it may not, at first glance, look appropriate from the regulator's perspective. And I have had some of those discussions in the past with the regulator and in fairness, more often not have found, actually that they're quite willing to accept, you know, valid evidence backed arguments from trustees when they put forward, is there an element to which everyone always blames the regulators. It's, it's, you know, it's it's it's an easy thing to say and feel a bit emotional about. But actually, that's pretty good and fairly interactive. If you're prepared to engage. Yeah, absolutely. I mean, it's a trustee, I'm quite sympathetic to regulate. They've got limited resources as well, I think, I think actually, as well, it's quite interesting the timing of bob's research here as well, that it perhaps comes at the time when a reasonable amount of regulation around investments for trustees has landed. So, again, that might be a contributing factor as to why a number of them were perhaps under a little bit of pressure from that regulatory side of things and maybe giving answers to questions at the moment? In that particular moment? As opposed to if you maybe ask them in a year or two, reflecting back on those regulatory changes, how did they feel? Did they feel it stifled their investment processes and decisions? Because ultimately, the Trustees are in control of those investment decisions, Not the regulator or anybody else. There, there is a direction that regulators heading in and it is tending to take trustees into taking lower risk, generally speaking. But ultimately, that's still a trustee decision, not a regulatory directive and sarah. If you've got a well run scheme, is this regulatory or is it a burden? Or is it do you get a bit of a sense that this is a lot of regulation directed at. Perhaps not particularly well run schemes, it might produce paperwork for you, but it's not a massive intellectual organizational challenge. Yeah, absolutely, you're quite right. It presents, it feels like a bit more of a checkbox exercise and I think you have to be careful having that view because these are important things that we need to be thinking about, but as you say, well, run schemes tend to be thinking about these anyway and there's a lot of new governance stuff coming in at the moment where the same applies where yes, you've now got to document exactly what you're doing, but you're kind of doing it anyway and it might be that you make sure you've got a new section on the agenda to specifically cover points, but they are around and you are thinking about them. Um it does feel a little bit like some of the things like an implementation statement who's going to read it other than me, but I do recognize that for schemes where they have not put any thought into it and they haven't got advisors that can help them or do help them that with these things, then it is important for them to start making giving that attention to these matters. Thank you, bob supposed to raise the whole issue as well of alternatives. Did you get much feedback from this as to whether people saw those high risk, low risk and whether they have the expertise to be on top of that as an asset class. No, it's a question in terms of the sort of investment decisions that they expressed, they wanted to make that there was some asset classes like infrastructure that score quite highly among the from from the first professional Trustees we spoke to. And that makes sense. Infrastructures as a logical long term investment for a pension scheme. In terms of the other alternatives, they all rated reasonably highly to, there wasn't any particular standouts, but it's certainly one of the observations I've always had around this is that alternatives really aren't a replacement for taking risk with equities and stock market investments. That, I mean, there are different types of investments, but it's not a like for like replacement, you're taking a lot less risk generally speaking, and probably getting a lot less return as well over the long term, at least that's what you should expect. So there wasn't any strong feelings either way either way on that. But certainly trustees felt that they wanted to take more risk with equities and and invest in corporate bonds as well. So credit risk as well then perhaps they felt they were able to do. And we didn't specifically ask them whether they are the reason why they weren't perhaps implementing their views as as clearly as they would have, like just because of regulation, but perhaps that's one of the concerns that there may well be a whole myriad of other concerns too. But she just contextualizing it because I think this research was conducted in august this year. So chris you know, you could argue that equity markets have had a pretty good run, yields have gone up a little bit on bonds. How much might that have affected people's attitudes, this they If markets are doing well, everybody wants to take a bit more risk. And I think 47% said their appetite for investment risk had increased since the pandemic. Yeah, I found that quite interesting actually. I found it interesting that there was a change in the appetite for risk post pandemic as opposed to pre irrespective of whether that was to take greater risk or less risk just because actually the potential risk out there hasn't really changed. You know, the risk for these market events has always existed and always will exist. And I was a little bit surprised if I'm honest that the outcome of that sort of research, because the level of risk that you're taking should be appropriate to the scheme, circumstances irrespective of what's going on within the market, I think that's down to the investment specialists to pick their way through the challenges of the where the particular returns can come from and so on within the investment markets. But as far as the trustee is concerned, you're targeted long term return should should be based upon what's appropriate for that particular scheme. And so I did find that that particular aspect quite quite interesting if I'm honest, in terms of the output from the research and Sarah final thought from this, I think 40% of those questions cited a lack of confidence in their investment knowledge as something that is the world fundamentally just getting more complicated. Um Yes and no, I think there is a lot of complicated areas where there are a lot of complicated areas in investments and I think trustees sometimes struggle to find that balance in how much they need to understand themselves and how much they can put effectively their trust into their advisors in things like infrastructure, which was one that that bob said was quite popular. Everybody understands what that means. It's sort of buildings and bridges and such and you you can you can kind of picture that. But some of the opportunities that are out there for investing can be a little bit more complex. And I think trustees like to be able to at least understand the basics before they're prepared to sort of almost bet the schemes money on it, because it's not just about what are we doing with our investments, you do have to have half an eye on or what if it goes wrong? Because this is a member of benefits we're talking about. And it's not, it's not as simple as what can we do with all this money. How can we make it do a lot for us? We have to bear in mind that if it all went horribly wrong, we've got members effectively footing the bill unless you go in the PPF. But even that's not great. Okay, well, I wanted to, I'm going to find another statistic at you because it's sort of segue into, into the next part of the program. Sarah, which is that almost two thirds of those questions expected to step down as professional trustees within the next three years. Again, did that surprise you? Is that an issue of demographics professional trustee is getting older and hitting retirement age themselves or is it something something to do with the pressures of the job? Yeah, Initially I was quite surprised by that. As you say, I know that there are quite a lot of older trustees. So in some ways that I suppose that is to be expected. But equally, I know there has been a large influx recently and there probably still is of, I'm going to say younger trustees myself included, where we recognize that whilst DB pensions in themselves might not be the future, there is still a lot of work to be done. And there are DC pension schemes to look after and a lot of those are trust based because we've got several of them and and things like investments, whether you're talking DB or DC is, well, the investments are the same, the principles are very slightly different. So it was interesting, but I do think that it needs some thought as to where we go as professional trustees and making sure that we've got all the right skills because we don't want to lose all that pensions expertise equally. The world changes very quickly and sometimes we need to move with the times. Okay, But what were your thoughts on that? Yes, so I was a bit surprised as well as I think, I think so. I was saying about the scale of which professional trustees were perhaps felt that they were likely to leave the role and the extent to which that was due to increased complexity when, when asked why and I do wonder whether professional trustees also has said or maybe all answering themselves the right question and doing the right roles because really your job is to have experts in all the different areas and it is complicated. There's a lot of different things, you got to be on top of as a pension scheme and as a professional trustee, you don't need to be an expert in every single one of them. You do need to have trust in the experts that you hire to do that. And honestly, that's one of the takeaways from the questions about investment risk as well, because there was lots of confused aren't confusion in the overall answers there some paradoxes, some answers that didn't make sense. And actually, when you think about it really that if you're working with a professional investment team, you do as a professional trustee, you don't need to make those decisions yourself, You should be perhaps looking for a professional team to make those decisions for you because it is technical and complex in the same way that you wouldn't have get it heavily engaged in the exact mathematical process of an actuarial valuation, you'd help set the parameters and then let the actually do their job and then test the results and kick the tires same true of investment risk, which is fiddly and complicated and difficult to get your head around unless it's your your day job. So I hope professional trustees aren't feeling like they need to step away because it's all too much for them and that and that there isn't enough support there from professional service providers like like ourselves. Okay, we'll take your point is but chris to do that, you've got to have the confidence to delegate so that you have to feel, you know, quite a lot to be able to hand the task over to the right people. What are your thoughts on where some of those potential knowledge gaps lie for for for professional trustees? Yeah, I think it is about, as bob said about asking the right questions if I can take it sort of off pensions for a moment, you know, if I was managing the restaurant, I could sit down with the head chef and talk to them about what's on the menu. I wouldn't necessarily have to be a chef, but I can ask them where they're sourcing the ingredients, Are they local? What have you got in terms of vegetarian options or vegan options on the menu? Where are the price points on the menu? How does that compare to the football coming through the restaurant? So on and so forth. You don't have to be necessary an expert at running a restaurant to have that conversation with the head chef. Exactly the same. When you're looking at that running a pension scheme is a trustee, you don't necessarily have to be an expert in covenant investment or scheme funding. You just have to know what sort of questions to ask and to be able to challenge and to see if what you're getting told is the answer is actually makes sense based upon what you're seeing yourself. How important is it that some of those you outsource to are providing this this knowledge? I mean, again, picking up on a, on a stamp from that, there are 45% of those interviewed believe regulations too complex and they lack support from official bodies. So who should you be getting this regulatory and perhaps investment knowledge from if you're not an expert yourself? Yeah, I mean, personally, I mean, I'm not just saying this because bob's in the room. I'm personally a big advocate of fiduciary management and that is because what you're actually doing is passing the bits that I don't think there's a massive amount of value in the trustee is getting involved in over to an investment specialist which which is around the sort of tactical decision making if you like. And leaving the trustees to deal with the higher level strategic thinking around investments. And I think that's what trustees are very good at. I think they are very good at assessing information, a simulating information and assessing the risks and journey planning and looking at the long term objectives of the pension scheme, whether they're on track, that's where trustees really have their specialist knowledge and that's where I think they should be focusing both from an investment perspective and covenants and everything else. Thank you. And sorry, just coming back on the point you were making earlier about there's a lot of work still to do in B. D. B. Space. But is it is it proving hard to attract people to the industry because the headlines are all that D. B. Is in a runoff? I don't think it is. I don't know if it's because the companies sort of the main companies that work in this industry are expanding and looking forward to the future. But my my understanding is that they're still managing to recruit quite actively across all of this area. And I think my uncle told me once that the people of my generation will have four different careers. So maybe people will come in and do this for 5, 10 years and then we'll go and do something else for, for the next however many years that we're working, but it's a very interesting place to work and nobody ever intentionally works in pensions, you all fall into pensions, um but it is interesting and you meet some interesting people and you get to do some interesting things and whether you specialize as an actuary or an investment advisor or whatever, but the thing I like about being a trustee as chris alluded to is the fact that you're taking that Broadview trustees role is to have a look at the whole picture and make sure it's all aligned, you get your investment manager to make sure that the investments are right in your factory to make sure your funding plans okay. And all your liabilities are managed and your administrators to make sure you're paying your members properly and your role is to make sure you've got that oversight and that you're making sure it's all tied in together. And I think that's where the, well that is, where the trustees have the value really agree with that, you know? Absolutely. And I think that we're also seeing quite a big shift change within the pensions industry as well. So, you mentioned about defined benefit pension schemes and that they are in demise, I mean, certainly that's true, the vast majority of schemes are not only closed any members, but are closed to future. Cool. And we have to recognize that the future of pension provision will be, will look very different, but actually, within the industry, there's still going to be a need for people that can govern whatever pension provision looks like over the next 30 40 50 or 60 years, and that will be people who are young and fresh into the industry and have got the new ideas and aren't saddled with a knowledge only of defined benefit pension schemes and that's all they're used to. It will be people that can see where the future's going with the future direction is, but that, that need for governance from trustees or whatever they're going to be called in the future will still be needed. And I think, member education, member engagement members understanding the risk that they're going to be taking with their pension provisions going forward are all key aspects to, to that particular role going forward, bob, I suppose you could argue professional trustees, you know, they worry about things because they know what the issues are the problems are. But if professional trustees are feeling a little bit beat up, perhaps on occasion in this space, how are the late trustees feeling? That's an excellent question, I guess. Well, I guess the issue for late trustees that they don't know what they don't know a lot of the time. So, I mean, very few of the pension schemes, the trustee board that I work with have no, have have no professional trustee these days, even the really small schemes I've got actually, I think it's more likely look at our client base that smaller schemes more likely to have professional trustees, maybe even sole trustee in order to manage everything. But it it's it's impossible. I used to be electricity myself many moons ago and especially for trying to make investment decisions or will you anything your heavily reliant on your advisors and you don't know what is normal practice. And that is I think the massive value of having professional trustees, you've got someone in the room who knows what it's like another pension schemes know what normal looks like knowing what good looks like. So therefore knows the right questions to ask of the advisors knows when they're seeing information isn't quite right or not understand? Excuse me. But I lay trustee would have no idea because they just don't know what it looks like in a different scheme. Now, I want to move on to our final topic, which is this issue of setting long term funding targets, which we've alluded to a couple of times. So chris I want to run this statistic pasture which came from the research, Fewer than 25% of trustees have set a long term funding target, 50% expect to do so in the next 12 months and the remaining 25% In 12-24 months. What makes it so difficult to set a long term funding target. Yeah, I don't think there's necessarily anything that makes it particularly difficult. I think what I'd read into those statistics is that there hasn't to date been a regulatory requirement to set a long term funding targets. And perhaps a significant number of trustees may have put one in place in the last few years if it weren't for some of the other challenges that they've had. Obviously with the pandemic and Covid, and we talked about some of the investment regulatory changes that have come in in the last 12 to 18 months as well, which have obviously taken up trustees attention, but certainly going forward, I would expect those numbers to increase quite significantly and over the relatively short term. And it is vitally important that trustees do set a long term objective because these pension schemes are ultimately at the end of a long term investment And, you know, there is a bit too much focusing on the short term, I think, particularly when looking at investment strategy and that tends to be driven by the fact that you have these triangle valuations. So, everybody really is, is hooked into what does it look like in three years time? Was perhaps they should really be looking at what it looked like in 30 years time. Well, picking up on that challenge, Sarah, how do you, how do you solve it and make sure that your long term and short term plans don't get too out of kilter. It's a difficult one. I think, fundamentally everybody is expecting to buy out at some point because that really has been the only option for pension schemes. There are lots of new options coming, I'm saying coming into force, there's sort of super funds and consolidators, but they're all very new. So I think there's a hesitancy among all trustees for kind of committing to any of those because nobody wants to be the first one into a, a new race. So I think there's an element of, well, we've always assumed that buyout was the endgame. And so we've kind of been funding our scheme on a reasonable basis that we can just about afford In the hope that one day we'll get to buy out in probably 20 or 30 years. So there's going to be a little bit of a shift and a bit of research needs to be done in terms of what alternative end games there are. Um, but it's going to fundamentally come down to whether you've got enough money or not, I think, um, and whether your employer wants to, or can afford to pay in extra funds, because again, it comes back to this managing the risk and finding that balance, it's all well and good saying right, we want to Buy out in 10 years time, but if you haven't got enough money to buy out and your employer can't give you any money, Then it's, it's just, you're never going to get off the starting blocks on that one. so how you align those two strategies, I think that's probably where the discussions are going to come into, isn't it? I completely agree. And I think demand will drive choice as well. You know, we've, we've seen that in other walks of life, probably gathering relatively old and old enough to remember that there are probably only two or three bottles of wine in a supermarket when I was growing up. You could get your Mattis Rose or you leave from elsewhere. You're black tower. Now it's two aisles full of wine in a supermarket because demand has driven that change. Same with the automobile industry that, you know, the, the, the driving electric cars for forgive the pun. But, you know, that's significant increase that we have there. And I think we'll see the same that as more and more schemes are coming towards buyout, which they will, you know, they have the limited sort of shelf life. These schemes, then actually, we'll probably see more innovation within that area, which may not be by out, you know, may not be super funds? It might be something different. Again, we don't know, but I think that demand will drive change and drive some innovation as well. But what are your thoughts that particular point, I suppose that if you've got a for, you know, the scheme could have 40 50 years to run if it kept jogging over, you'd say, well you've probably taken quite a lot of equity risk, but if you look at the regulations, they'd probably say, I don't know that, that's exactly the point. And if, and if Sarah's right, and that's, I think she is that almost all mexicans will buy us at the end. Unless there's some technical reason why that's not possible, then actually your goal is very much linked to the long term interest rates that force everybody to take a short term view. So that that's that's the irony. So, the problem with the tri annual process is that you're fixing your deficit based on long term interest rates that for a lot of companies and pension schemes, thinking nonsense because they're gonna be running the pension scheme forever. Who cares what interest rates are. You know, the company is bound to be in here, 30 has been, it's been around 30 years, is going to be here another 30 years time. So it's very, very long term, but, you know, it's not an endowment, it's not, I mean, we've got some clients of endowments, the genuine, that's proper long term investing there because they're gonna be around forever. And that's the that's the intention anyway, so that's a long term. But for, for most defined benefit pension scheme is much shorter term horizon than that. And obviously by us a long way off for them, then that, that timeline is probably a real one, but it's coming in closer, we've seen a lot more schemes buying out this year due to market conditions changing, I expect that trend to continue. So you're writing that it is gradually declining, but the rate of its decline will be, will be determined by how affordable buyout is and it is getting, it's getting cheaper and easier for lots of schemes at the moment. And chris is there a bit of a paradox here that the closer you come to being fully funded on a technical basis, the less likely an employer is too top the scheme up and perhaps push, push you just over over the edge into the wonderful world of buyout liabilities off your plate. It does very much depend on the nature of the business and what's driving that thought process from the finance directors and the others that are running that company, if you're dealing with an organization where it's perhaps in the finance directors interests to keep costs low for the next few years because that is going to determine their remuneration, and they may then be thinking about moving on somewhere else on the back of that or whatever, then actually they may be just very much cost driven and want to pay as little as they can get away with into the pension scheme, then you have others who have a much more longer term view on things, particularly only managers of small businesses where, you know, they've got to think about an exit strategy for their business and if they've got defined benefit pension scheme on the books, that's not going to help them with that exit strategy and also others where they'll be acquisition and merger activity, where you know that it could be impeded by having a defined benefit pension scheme on the books so that the organizations for whom it's, it makes strategic and business sense to go towards buyout and there'll be others where for financial reasons they're wanting to and for selfish reasons of wanting to actually avoid paying a significant amount of money into the pension. Okay. And well, Sarah I statistic from, from research, 73% of those questions think buyouts are unreasonably expensive, are they? Are they right, possibly. I mean, just picking up one last point on, on what we've been talking about just now is that there's always this thought in the back of trustees minds that what if the company goes bust? And I know that there are some companies who have been around 100 years and reasonably expect them to be around another 100 years, but there will be some that just all of a sudden drop and as much as you're trying to keep an eye on the company, sometimes you just don't get enough information, but coming back to your question, it is expensive, but we've been looking at this in particular for one of my schemes recently and I think it depends on your liabilities and the nature of your liabilities themselves Fundamentally, it seems to be that if you've got old people, insurance companies, like sort of don't mind ensuring them because it's an awful lot easier to predict when they're going to die, I'm sorry, but when you're younger there's just too much uncertainty. So it becomes very expensive because they're just not prepared to take those risks. The insurance market has much more strict regulation than we have, and they have much stricter um solvency and financing requirements. So My understanding is that they're not prepared to take as much risk on those younger liabilities. So if you've got a 40 year old, well he's not gonna retire for another 25 years. And a lot can happen in that time. And you don't know how long he might live another 30 years beyond that. So that's a 55 year commitment they might be making. So of course, they're going to be cautious. So I can see why they price the way they do and I can sort of support that. But equally, it doesn't help us from a pensions perspective. And final thought on this is that problem that Sarah's described gradually fading away, given that more, you know, schemes are closing two new members, it's an aging demographic that tend to be in DVD schemes, it's definitely diminishing over time because you say, as almost all schemes are closed to new members and most of them to new cruel to, So gradually, that's a declining uh declining population. And as the members get older, so it says, get nearer retirement, that's more attractive for an insurance company. It's also market pressures as well, more insurance companies competing with each other. Plus also the prospects of consolidated funds coming into the market, which will be a direct rival to buy out companies and you know, that is a, is affecting the way these deals are being christ, so that is a natural competitor to them. So it's a it's a combination of those factors. We have to leave it there, I'm afraid bob. Campion, sarah marshall and chris Halewood. Thank you all very much. Mm hmm mm mm hmm.


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