LGPS: All change at the top

An action focussed update for employers on the government’s Pensions Review

In the last year the LGPS has come right into the political limelight. It started with Jeremy Hunt’s Mansion House speech and continues with the new government’s recent Call for Evidence on pensions. We have provided a bite-sized update below, including some next steps for you as an LGPS employer to consider.

In short, we believe this could lead to your fund investing more heavily in risky assets than you would want and/or merging with other funds. There is also a possibility of more radical change.

As an employer, you can help shape the LGPS for your direct benefit and for the whole LGPS employer community. This is especially timely given the imminent actuarial valuation and the current very good funding positions.

Note: this update is for employers in the LGPS in England & Wales, but not Scotland or Northern Ireland

Background – LGPS layers

The LGPS comes in three “layers”:

• In the middle: 87 separate LGPS funds across England & Wales
• At the top: 8 investment pools, each LGPS fund is in one. Not one-size-fits all in terms of their operation or progress, around 70% of the LGPS assets are managed by the pools
• At the bottom: nearly 15,000 employers each with their own notional share of fund

The use “top” and “bottom” shouldn’t be seen as hierarchy – there would be no LGPS without its employers. However, it feels natural to consider the consolidated entities as sitting above their constituent parts.

The Mansion House speech

In July 2023 Jeremy Hunt’s Mansion House speech began with pensions. He wanted all UK pension schemes to be investing more in the UK and for this purpose he divided up the UK’s pensions assets into three key areas:

• Defined Contribution (DC) schemes
• Trust-based Defined Benefit schemes; and
• LGPS

For the LGPS this was very significant and signalled a new era of focus on the assets, with emerging surpluses having taken the pressure off funding the liabilities. Inevitably, the focus was on investment pooling and whether this could be made more effective.

A consultation on improving investment pooling followed shortly after and was very quickly responded to by government demonstrating their intent to get more LGPS assets into UK private equity markets and investments specifically focussed on social and regional outcomes (previously “levelling-up”). The government then had their eye on having a smaller number of larger pools in the top layer rather than eight to increase the benefits of scale.

Ministerial letter

In the run up to the June election, the then Local Government Minister, Simon Hoare, kept his foot on the gas. There was some talk of merging the LGPS middle layer down to eight LGPS funds rather than the current 87. And then in May, as a parting shot, he wrote to all LGPS funds in England to ask for evidence of their pooling progress and cost savings, hinting that fund mergers (middle layer) would be beneficial.

At the same Labour were picking up the baton and seemingly “doubling down” on the Conservative party’s LGPS consolidation intentions. Rachel Reeves also talked of a reduced number of LGPS funds and indicated that she saw the assets as contributing towards a possible sovereign wealth fund.

Labour’s Pensions Review

Labour have acted quickly, announcing a Pensions Review in August. And last week they issued a Call for Evidence with only a three week deadline. They have realised that trust-based Defined Benefit schemes are too long in the tooth for radical change – they’ll be tinkered with through secondary legislation. So all eyes are on the LGPS and DC, previously very unlikely bedfellows.

There has been a lot of interest in the Canadian pensions model. Evidence would suggest that the so-called “Maple 8” group of the biggest Canadian public pension funds have performed well. However, whilst some lessons can be learnt there is no easy way to overlay the Canadian approach onto the LGPS.

A hugely radical step would be to detach the LGPS assets from its liabilities. This would enable the LGPS assets to be run as a sovereign wealth fund with global scale (assets of over £400bn). We expect this to be considered. However, it would be a complicated and onerous task and would get significant push back.

LGPS surpluses

The LGPS was, on aggregate, in a healthy surplus as at 31 March 2022 actuarial valuation date and it is in an even better position now – in a healthy surplus even on a low risk basis. But there is very little public commentary on this other than Isio’s Low-risk Index and it is not entirely clear if the government is aware of the challenges and opportunities this brings:

• Challenge: with many employers in surplus and preferring to de-risk, is it right for the government to ask the whole of the LGPS to invest more in private equity and other growth focussed assets?
• Opportunity: many £bns could be released to LGPS employers to facilitate UK economic growth via contribution reductions. Would this be easier than trying to influence how the LGPS’s assets are invested?

The LGPS employer layer

There is very little mention of employers in public discussion. This is perhaps understandable given the government’s top-down view of the assets. However, it is also about the fact that, in general, employers don’t have a clear voice. It is not easy when there are nearly 15,000 of you, but for many decades funds have tended to operate with little reference to their employers.

However, there is a risk that change could have unintended consequences for employers, for example if your fund:

• invests in a riskier way than you wish to support
• merges, changing the approach to setting contributions and managing employer risks
• merges, changing the experience for your employees and former employees.

There are also opportunities.

• If you are frustrated with your fund, could change be helpful?
• Might bigger funds be able to support your organisation’s investment needs, the needs of your sector and a positive experience for your own members?

Proactive steps

We are concerned that the pools and the funds have been drawn into this “top down” discussion and are not highlighting to government the “bottom up” complexity they face with so many employers. Highlighting the underlying employer base of the LGPS might put off government from interfering with investments, for example.

With this in mind, possible steps you could take include:

• Formulate your preferred outcome for LGPS
• Ask your Fund for their response to Simon Hoare’s Ministerial letter
• Ask your Fund if and how they are responding to the Call for Evidence
• Respond directly to the Call for Evidence
• Find out your Fund’s intention in relation to mergers
• Find out your Fund’s current position (how much is pooled?) and their next steps on investment pooling
• Assess the level of investment risk you are taking and want to continue to take

Isio will be responding to the Call for Evidence and will make this available on our website.

We would be happy to discuss this with and will keep you updated on further developments.