Ebere Nwoji
A Chartered Insurer and former Managing
Director of Linkage Assurance Plc, Dr. Pius Apere, has kicked against
the multi-fund investment structure introduced last year by the National
Pension Commission (PENCOM), stressing that the Pension Fund
Administrators (PFAs) have not created
enough awareness on the
initiative.
Apere, who stated this at a forum in
Lagos, also warned that contributors may make inappropriate investment
decisions due to the lack of knowledge of the plan.
Fund administrators, he added, can
reduce the risk by providing access to education, advice and/or
communication to ensure that contributors understand what is being
offered and the potential consequences of the choices that they make.
However, he stressed that doing this would be at a cost to PFAs.
Apere also said projections of the
future pension benefits would be more complex because of many overlaps
between some fund types, “thus, the range of investment options (Fund
Types) provided will impact on cost of administration of Pension Fund
Administrators.”
He further noted that for a defined
contribution scheme that offers an underpin (a guaranteed minimum
pension), there is a risk that members of the Contributory Pension
Scheme will choose a more risky investment strategy than they otherwise
might have, “since they know they have a minimum benefit promise or
members will choose a very safe investment strategy with relatively low
expected returns.”
He further noted that a pragmatic
approach for allocation of investment returns within a given fund type
amongst contributors may be adopted to take into account of each
individual contributor’s asset under management (AUM) and/or duration
profile (in years) within the fund type.
Apere concluded that the implementation
of the Multi-Fund Structure for Contributory Pension Scheme under PRA
2014, was expected to maximise the investment returns for Retirement
Savings Account (RSA) holders prior to retirement and that this would in
turn likely to increase their pension benefits at retirement.
He emphasised in the need for
involvement of Actuarial knowledge and ideas in the pension fund
investment, adding that it was traditionally thought that members in
defined contribution (DC) schemes bear all the investment risks and
rewards and receive benefits (based on whatever contributions and
investment returns are produced at retirement), which are adjusted
automatically.
According to him, contrary to this, a
Defined Contributory scheme such as the Contributory Pension Scheme
(CPS) operating in Nigeria that forces compulsory contribution according
to section 4(1) of PRA 2014) and entails significant tax concessions
(section 10 of PRA 2014) should not, under reasonable circumstances, be
left to require members to bear all risks over many decades of
membership.
This according to him necessitated the
introduction of guaranteed minimum pension (GMP) as an underpin (section
84(1) of PRA 2014) .
Describing the development as quite
appropriate with the aim to reduce the risk of volatility of standard of
living in retirement facing the pensioners, Apere said conceptually,
the determination of the GMP and the appropriate investment strategies
requires an actuarial methodology.
He suggested that in view of the above,
PENCOM should also be aware that offering even a minimal defined
benefit(DB) underpin can result in the CPS needing to meet DC regulation
as well as DCregulatio
He noted that prior to the introduction
of the multi-fund structure in July 2018, the PFAs operated low risk
investment strategies, without taking into account the scheme members’
duration (age) / risk profiles and their freedom of choice of investment
funds.

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