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Turn 401(k)s into Bond Ladders

Posted on March 18, 2020 by -

Bond ladders or certificate-of-deposit ladders are tried-and-true techniques for establishing predictable yearly income in retirement. But they currently have drawbacks. CD rates are too low, and bond ladders require large investments. Neither can be built by 401(k) plan participants prior to retirement.

One easy alternative is to use defined maturity funds (DMFs). These diversified bond funds combine the best features of a bond ladder and a bond fund, either as insulation from interest rate risk or as a safe stairway of annual income in retirement. Invesco and BlackRock offer them as exchange-traded funds (ETFs). Fidelity offers them as municipal bond funds.

Franklin Templeton distributes its defined maturity bond funds through retirement plans. The firm brought its first DMF to market in 2015, but it got little traction. The passage of the SECURE Act in December could change that by helping to reframe the 401(k) as a generator of retirement income.

“Prior to the passage of the SECURE Act, plan sponsors were broadly reluctant to embrace the income challenge,” said Drew Carrington, senior vice president and head of Institutional Defined Contribution at Franklin Templeton, in a recent interview with RIJ. “That was primarily because of the annuity selection liability issue.”

Carrington was referring to plan sponsors’ concerns that they could be sued if a life insurer who sold annuities to their participants later defaulted. “Decisions about products like ours, that have no insurance component, have also been held up [by those concerns],” he said.

Drew Carrington

“We’re hoping that passage of the SECURE Act will drive renewed interest and spur action. We’ve seen a couple RFPs [requests for proposals] from plan sponsors. We hope that this may represent a turning point in the acceptance of retirement income options in 401(k) plans.”

Franklin Templeton’s institutional DMFs are liquid, actively managed diversified mutual funds containing a mix of investment-grade, non-callable bonds that all mature in the same year. There are no mortgage-backed securities or floating-rate bonds. They are structured so that plan participants who have retirement spending needs in 2021 might invest in a 2021 Fund, a 2022 Fund, etc. The current expense ratio is 32 basis points (0.32%) per year.

The DMFs are intended to fit the contribution and accumulation pattern of a 401(k) participant. “Every two weeks a person could purchase small slices of a fund. Other people might reach age 60 and decide to buy a five-year bond ladder all at once. Other people might say, ‘I’ll buy a new fund every year for five years,’” Carrington said. “You can go either way. The funds have liquidity and a daily price. The closer they get to maturity, the less volatile their value will be. If you sell the fund prior to maturity, there could be a market value decline. But barring a default the fund should mature at its par value,” he added.

DMF ladders can be extended indefinitely, but Franklin Templeton envisions ladders of five years. “Our theory was that that’s about as far out as most people have a sense of planning for. If you ask them what their income needs will be in a year, they can usually tell you. But if you ask them how much they’ll be spending in 12 years, they don’t know. So we created a five-year program, with one fixed maturing fund for each of the five years.”

There’s a stereotype of rank-and-file retirement plan participants as largely disengaged from their retirement savings. Franklin Templeton also wondered if most people are too focused on yield and internal rates of return to appreciate the predictability of a ladder. “Some initial feedback from plan sponsors was that participants wouldn’t understand this, so we held focus groups,” Carrington told RIJ. “To ensure a broader swath of the US population, we made a point of conducting them in states such as Texas and Illinois instead of focusing on financial hubs like New York. The groups consisted of people over age 50 and currently participating in a 401(k) plan. Otherwise, they were as demographically diverse as possible.

“The interesting finding was that people immediately grasped that this was like a CD. They weren’t hung up on the yield component. They understood that you’d dedicate a portion of your savings today to the payment of certain expenses in the future. People thought of it as bucketing.

“We often heard people say, ‘I could set aside dollars to pay for a certain expense, like property taxes. Then I wouldn’t have to worry about that expense and I could spend my other money as I wish. One person asked, ‘Can I do this in different amounts each year?’

“As a general rule, the defined contribution industry tends to underestimate participants’ financial literacy. However, from our focus groups, we found that people intuitively grasped this product. I am now more inclined to think that participants close to retirement have a better sense of what they need than the industry gives them credit for.”

Franklin Templeton envisions participants using a bucketing strategy, where one income bucket consists of a DMF ladder and a later income bucket of a deferred annuity, or QLAC, or qualified longevity annuity contract. Created by the U.S. Treasury in 2014, QLACs allow Americans to buy late-life deferred income annuities with up to 25% of their tax-deferred savings (to a maximum of $135,000 for 2020) without violating the requirement to start taking distributions from tax-deferred accounts after reaching age 72.

The asset management firm asked retirement experts from The American College to run Monte Carlo simulations of the hypothetical performance of a Franklin Templeton DMF ladder, a portfolio of growth funds, and a MetLife QLAC during retirement to see if it outperformed the traditional 4% “safe withdrawal rule” established by William Bengen in 1994.

“We asked Michael Finke and Wade Pfau to answer the question, ‘If we think about risks like volatility and longevity risk in retirement, would a combination of a bond ladder, a QLAC and a growth portfolio outperform the 4% rule on those two metrics, and their answer was ‘Yes,’” Carrington said.

“The research is compelling on that point. If your goal is wealth maximization on average and you care only about that, the answer is ‘No.’ Higher equity allocations create the potential for higher ending wealth. But they create a wider dispersion of outcomes in terms of income variability and longevity risk.”

Carrington sees the potential to partner with an annuity issuer on products that combine DMFs and QLACs. “We’re not officially co-marketing with an insurance company, but we are certainly open to joining into a conversation with others. That’s why we did the joint project with MetLife and The American College,” he told RIJ.

Carrington imagines the following scenario. “Most people will retire in their early 60s, draw down Social Security in their mid-60s and buy a QLAC that starts in their mid-80s. So we’re looking at a 10- to 15-year window for these bond funds,” he said.

“In that framing, if you make a back-of-the-envelope assumption that people can put up to 25% of their qualified savings into a QLAC, and put five percent into each year of your five-year bond ladder. That’s a total of 50%. The other half of the portfolio is left to address income needs and inflation risk in the years [between the end of the bond ladder and the beginning of the QLAC income].

“HR departments tell us, my participants aren’t asking for income products. But we say, there will be second order effects. Think about rearview cameras in cars. Nobody knew they wanted rearview cameras until they had them. Now they get in a car without one and say, ‘Where’s the rearview camera?’”

© 2020 RIJ Publishing LLC. All rights reserved.

A response to last week’s cover story

Posted on March 12, 2020 by -

Thank you for including a synopsis of the Shoven et al. study in Retirement Income Journal. In your summary comment on the Shoven article, you stated:

“The paper suggests that it doesn’t make much sense for people in the bottom half of the income distribution to defer Social Security benefits until age 70 or to buy life annuities.”

Much of what Shoven et al. observe is correct. But I don’t agree that negative real interest rates necessarily imply that there’s no reason to defer Social Security benefits until age 70 or to buy life annuities (particularly deferred life annuities).

Let me explain.

Under current practices, Social Security benefits beyond 62 years of age tend to increase by roughly 8% per year of delay up to age 70. This is due to the mortality assumptions and the assumed interest rate embedded in those increments. Because the 8% yearly increment (which remains inflation-adjusted throughout the remainder of life) is higher than can be justified on economic and actuarial grounds, it still may be a good choice to delay Social Security until later years, even 70.

In addition, the tontine nature of life annuities, and particularly deferred income annuities, means that their high “mortality credits” should continue to attract new buyers, despite very low or even negative embedded real rates of interest.

Arrow, Debreu and Hirshleifer provided the theoretical basis for that attraction in their Nobel Prize elaborations of “state-preference theory.” They showed that the value that one places on money depends upon the state of nature, including the individual circumstances, under which money is received.

In such states, one may use negative discount rates to assess annuities’ future value, thereby leading to potentially attractive returns. Thus, annuity payments that are “loaded up” with mortality credits can be particularly valuable, especially when someone can’t work or is dependent on assistance from a possibly insolvent government.

Even if the government is able to honor its promises without debasing its currency, the mortality credits will create impressive returns for those who survive beyond the average lifetime.

Dave Babbel                                                                                Professor Emeritus, Finance and Insurance                                      The Wharton School, University of Pennsylvania

Vanguard reboots a managed income fund

Posted on March 12, 2020 by -

Vanguard has changed the name of its Vanguard Managed Payout Fund to Vanguard Managed Allocation Fund. The fund also added a new portfolio manager to its team, effective immediately, and eliminated monthly payouts in favor of an annual distribution. The last monthly payment will be made in May.

The fund’s structure, composition, and investment advisor won’t change. It remain a fund-of-funds, investing in equities, fixed income, commodities, and alternative assets through other Vanguard funds. Vanguard Quantitative Equity Group (QEG), the firm’s internal active fund advisory arm, will continue to manage it.

The fund currently invests 52% of its assets in stocks, 23% in bonds, and 25% in alternatives. The fund is expected to retain an expense ratio of 0.32%.

Vanguard introduced three managed payout portfolios in 2008, each with its own target payout rate in retirement. But the financial crisis hurt the launch and the product sputtered. In 2014, the portfolios were merged into a single Managed Payout Fund with an annual target distribution rate of 4%. The fund has attracted only $1.9 billion. Most shareholders reinvested their distributions instead of taking monthly income.

Vanguard advised investors who want a regular stream of cash distributions to establish an automatic withdrawal plan from their Vanguard accounts.

Vanguard Managed Allocation Fund will continue to invest in a diversified portfolio of Vanguard funds, including but not limited to:

  • Vanguard Total International Stock Index Fund
  • Vanguard Alternative Strategies Fund
  • Vanguard Total Bond Market II Index Fund
  • Vanguard Total Stock Market Index Fund
  • Vanguard Global Minimum Volatility Fund
  • Vanguard Commodity Strategy Fund
  • Vanguard Total International Bond Index Fund
  • Vanguard Ultra-Short-Term Bond Fund
  • Vanguard Value Index Fund
  • Vanguard Market Neutral Fund
  • Vanguard Emerging Markets Stock Index Fund

Vanguard is positioning the revised fund for several audiences: As a cash-flow management tool for endowments and foundations, as an in-plan retirement income solution, or as part of a retirement income strategy for individual investors and their advisors, or as a diversified asset for institutional investors.

Vanguard’s Quantitative Equity Group was created in 1991. It is comprised of 37 portfolio managers, strategists, and analysts, and manages assets worth more than $44.5 billion. It is led by John Ameriks.

Fei Xu and Anatoly Shtekhman, managers of Vanguard Alternative Strategies Fund and Vanguard Commodity Strategy Fund, will manage the Managed Allocation fund’s portfolio.

Shtekhman earned a B.S. in mathematics from the University of Scranton, an M.S. in finance from Boston College, and an M.B.A. from the Wharton School of the University of Pennsylvania. Xu received a B.S. from Beijing University, an M.S. in geophysics from UCLA, and an M.B.A. from the Fuqua School of Business, Duke University.

© 2020 RIJ Publishing LLC. All rights reserved.

Stay Calm, But Nimble

Posted on March 12, 2020 by -

For retirement income planning in this chaos, the years before you retire should be the key consideration:

If you’re at or near retirement, “selling out” of the market is going to make the “sequence of return” issue a reality rather than a mere risk. Still, these market moves can be a wake-up call to put a strategy in place to make sure it doesn’t derail your retirement. (At left: Wade Pfau.)

If you’re years away from retirement, and have the stomach for it, there are some opportunities for loss harvesting and discounted stock buying. (Just remember that you could also be taking a bad thing and making it worse.)

We’ve been financial services witnesses to all the U.S. financial crises beginning with the near-hyperinflation of the early 1980s. These are the lessons we learned:

  • No two situations have been the same.
  • This one’s been a somewhat predictable disturbance to the supply chain; the 2008 crisis was more related to a liquidity crunch.
  • The “dot.com bubble” was consumer overconfidence followed a correction scenario. So, the exit out of this situation may be very different from the past.

What the financial crises of the past had in common was the tendency of too many people to sell low and buy high. A page from the financial playbook suggests not to do panic selling.

At the tactical level, there are opportunities in retirement planning:

  • Be prudent about how much conservatism you want to bake into your approach. Given today’s low interest rate environment, you’ll need to save even more in bonds if you shift away from stocks.
  • A simple rule to follow is to look at your portfolio balance on the date you retired, and whenever the current balance is less than that number, draw down from the buffer asset. Otherwise, you withdraw from your portfolio.
  • Investors with a whole life insurance policy can also potentially borrow from the cash savings component of their plan, since it is later repaid by deductions when the death benefit is paid out.
  • If you believe the market will correct, particularly if the current situation is hurting your income, now may be a great time to make conversions to Roth IRAs (and pay a lower tax).
  • If you have the time and stomach for it, harvesting losses now with a reinvest in a correlated asset may work for you. It may give you a tax deduction without changing your economic position.

On the flip side of this, particularly if your income is temporarily down, realizing income may make sense. For example, surrendering some of the IRA that you were going to surrender next year anyway could work. If you own a business, collecting on receivables or selling appreciated inventory (especially if that inventory is in demand) might generate some lower-taxed income.

© 2020 The American College. Used by permission.

A Reminder that Market Risk Is Real

Posted on March 12, 2020 by -

Panic is not a productive response to any situation, no matter how serious. Panic attacks are often abject cries for help that, by themselves, are purely counter-productive. Better to remind yourself that “intelligence is knowing what to do when you don’t know what to do.”

Then relax and wait for your brain to suggest the next move. It will.

But what about your panic-stricken clients? A lot depends on how old they are. One adviser I know faced a phone meeting this week with a fairly new client whose assets he hadn’t yet had a chance to reallocate. The client, a 62-year-old business owner, had had $700,000 in equities until 10 days ago.

“I’ll tell him three things,” the adviser said. “‘First, at your age, you should have been more diversified. Second, you can do nothing and ride it out. Or you can move 40% of that account to a fixed indexed annuity right now.'”

I don’t know yet how the client reacted. The client apparently also owns a fair amount of whole life insurance. This particular adviser often recommends life insurance for affluent retirees, both as a source of cash during moments like these and as a counterweight to a life-only single premium immediate annuity.

Of course, there’s an upside to downturns. “Stay the course” is the Boglehead response. But the bigger the drop, the bigger the opportunity for those with cash or near-cash. We love other products when they’re “on sale”: why not equities? If you were 50:50 in stocks and bonds before this correction, maybe you should rebalance toward stocks. Think of it this way: the market just regained a lot of equity risk premium.

Life insurers/annuity issuers can use this crisis to gently remind retirement savers and investors that risk is still real—and that insurance products and managed volatility products can help them sleep easier. (The Alliance for Lifetime Income should be busy this week with a follow-up to its “M.U.G.” promotion.) For life insurers who are buying back their own stocks, I assume this slide to be a windfall. For firms with big books of variable annuity business, the slump probably hurts fee revenue. Another interest rate cut certainly won’t help the sale of new fixed annuities.

The retirement conference schedule is being disrupted as we speak. The March 22 Adviser2X conference in New Orleans has been postponed until late July. I’m waiting for updates from Investment News, LIMRA, and the American Retirement Association about their retirement summits, all of them set for late April.

For basketball fans, March Madness is turning into March Sadness. As a college hoops fan, I’m following developments this week. The Ivy League cancelled its tournament. So far, the NCAA appears to have decided that the show will go on, but not before live audiences. Victory over the virus is more important.

© 2020 RIJ Publishing LLC. All rights reserved.

An Actuary Assesses COVID-19

Posted on March 11, 2020 by -

As the world grapples with the growing COVID-19 (coronavirus) threat, a useful reference point is the Spanish Flu of 1918. Given what we now know about COVID-19, are we looking at something of similar severity to the Spanish Flu, or materially less severe, or perhaps worse?

Up until now, the Spanish Flu has been generally regarded as a “worst case” reference point in pandemic modeling: This is as bad as it could get.

The thinking would be that healthcare is so much more advanced now, and we are not recovering from four years of strategic war as was the case then. These positive factors should more than compensate for the (then unimaginable) extent of international air travel and globalization of trade. But perhaps that rationale no longer holds, and we could be heading for something similar.

Plausible mortality impacts

Matthew Edwards

An actuary’s immediate reaction to COVID-19 is, of course, to model it. But even now, with more than two months of data, there are considerable obstacles to any plausible modeling using the typical pandemic modeling methods (e.g. the ‘SIR’ approach of splitting people into the states of susceptible, infected, and recovering, with age/gender-specific transition rates) and this article does not attempt any such modeling.

Most pandemic models involve a “spread” assumption, R0, which represents how many individuals an infected person will transmit the virus to (in an otherwise perfectly susceptible population). An R0 parameter of one, for instance, equates to a stable state; a value greater than one (at the start of an outbreak) implies growth in infections, with the potential for exponential growth in the absence of interventions. Normal influenza spread implies a parameter of two to three whereas measles is one of the most contagious viruses with an R0 of 12 to 16.

At the moment, even this fundamental element is uncertain by a wide range. Various publications so far have it ranging from 1.4 to over six, while even the World Health Organization’s (WHO’s) suggested range allows almost 100% variation (from 1.4 to 2.5).

In addition, as a further complication, the effective rate of reproduction will differ between countries and also vary over time as people shift their routines to avoid infection (hopefully decreasing as people and governments become more aware of the problems).

Then we have the problem of mortality, the case fatality rate (CFR), which measures the mortality of infected cases. Overall estimates are around 2%, but here there is wide variation between the experience in Wuhan (above 5%) and outside that area (of the order of 0.7%). Reporting and data issues add further uncertainty; even determining the number of cases is challenging, especially given the asymptomatic cases whose number cannot accurately be measured.

These figures compare with the following reference points:

The overall CFR in any country is likely to be heavily influenced by the availability of appropriate healthcare resources. However, the age variability seen so far is likely to be similar across countries.

The Chinese experience showed mortality rates varying broadly and exponentially by age, from circa 0.2% for ages up to 40, increasing to 4% for the 60 to 69 age band, 8% for the next decade of age, and roughly doubling again to 15% for anyone 80 or older. (This concentration of deaths at higher ages is supported by observation of the ages of reported European fatalities.)

So what sort of impact is plausible? To paint a very broad picture, if we assume a CFR in the 0.5% to 1.0% range (in line with the ‘outside Hubei’ COVID-19 figures to date, and the 1957/68 pandemics), this could lead to, as a plausible order-of-magnitude conjecture, a doubling of mortality in a country such as the U.K. for a period of several months. That is, an overall doubling of population mortality, not a doubling of mortality for infected cases. This would be a bad outcome (and is not a ‘best estimate’ prediction), but it is plausible.

Moreover, the above broad-brush perspective deliberately overlooks various likely and material indirect impacts. The likely surge in patient volumes at healthcare facilities related to a sustained COVID-19 outbreak in any country could mean a corresponding squeeze on access to care (and hence, increased mortality) for patients already suffering from other serious conditions in secondary care. There will be an equivalent but less severe effect at the primary care level.

Quarantine and self-isolation will also have a detrimental effect on those suffering from chronic conditions at home. The healthcare workforce will itself be depleted by absences. Furthermore, supplies of medicine taken for granted will potentially be adversely affected by production supply chain issues.

There is one material mitigating point from an insurance perspective, if not from that of the individuals affected: the coronavirus will disproportionately affect the less healthy (in particular, people already with chronic conditions), and hence the mortality impact does not consist entirely of ‘new’ deaths but will include a material proportion of ‘accelerated’ deaths (hence leading to correspondingly reduced mortality in later years).

A more positive point for insurers is the opportunity for innovative product design in the face of a very clear set of consumer concerns. By way of example, Generali announced in February a new product aimed specifically at providing coronavirus cover for healthcare costs and loss of earnings; other major insurers have launched similar products.

Impacts for insurers

The variability of the mortality impact by age makes the impact highly variable by type of insurer. Clearly, annuity writers will experience an unusually high mortality year (even under the more benign scenarios). Protection writers will see a mortality impact likely to be of similar order of magnitude to their capital allowance for life cat risk (for example, the Standard Formula of Solvency II sets this at 1.5 per mille, and internal model firms will have generally similar calibrations); the major question for them is the extent of their reinsurance.

The main losers will be firms with large whole of life books but low levels of reinsurance: there is likely to be a large amount of sum at risk for policyholders in their 50s and 60s, with a material mortality impact from the COVID-19 outbreak.

However, there are a range of other impacts that insurers with well-developed risk management functions and capital models should already be prepared for (one silver lining of the COVID-19 problem is that it does focus minds on real-life examples of complex interacting risks stemming from just one driver).

Asset markets are clearly badly affected, with (by way of example) the FTSE-100 down 12.7% and the S&P 500 down 8.6% from January 1 to February 28 this year. Operational risk will be a concern, with firms needing to prepare for significant staff absences, and absences in their suppliers (third-party outsourcers will not be “immune” to the problem themselves).

Occurring as this outbreak has immediately after most firms’ year-end means that insurers will have a couple more months to wait and see before finalizing their revised assumptions for mid-year reporting. By this time, mortality assumptions are likely to need increasing, probably with a short-term adjustment, while annuity writers might find it reasonable to wait and see as far as base assumptions go, noting that they can be fairly aggressive this year with improvement assumptions.

For instance, in the U.K., this is likely to mean no insurer will want to move to the latest mortality projection model CMI_2019, which gives slightly higher life expectancies than the previous versions. (In theory, the proper approach would be to combine a short-term adjustment to base tables with incorporation of CMI_2019, allowing for greater life expectancy for survivors. In practice, the uncertainties that will persist until even end 2020 will likely mitigate against this approach.)

In an ideal world, actuaries would wait for near-certainty before changing any major assumptions. In the first half of 2020, such an approach is unfortunately not feasible.

© 2020 WillisTowersWatson. Used by permission.

 

 

 

 

 

 

 

 

 

Bonuses enhance yield in Allianz Life’s new indexed annuity

Posted on March 5, 2020 by -

When stocks and bonds are trading at record or near-record prices and risk premiums shrink to almost nothing, investors, advisers and product developers have to get creative in their search for safe yield. All of today’s fruit is high-hanging.

In the absence of attractive bond yields, some life insurers offer annuity contracts with bonuses. Allianz Life of North America has led the indexed annuity market for some two decades with its bonus products. It rolled out the latest version this week.

Allianz Benefit Control is the product’s name. If the contract owner earns an annual credit from the appreciation of the underlying equity index-linked options, Allianz Life enhances the credit and, as directed by the owner, adds it to one of the two sleeves in the contract.

One sleeve is the contract’s account value. That’s what owners receive if they cash out today (net of surrender fees and market value adjustments). The second sleeve is the “protected income value” or PIV. The insurer multiplies the PIV by an age-adjusted payout percentage to calculate the annual income that owners can receive for the rest of their lives.

Owners who want the highest possible future income can raise their PIVs by 250% of annual earned interest, if any, and also raise their account values by 50% of their earned interest. In other words, if someone earns 4% for the year, the PIV goes up by 10% and the account value goes up by 2%. That’s option one.

Alternately, owners can raise their PIVs by 150% of earned interest and raise their account values by 100% of earned interest. If someone earns 4%, the PIV goes up by 6% and the account value goes up by 4%. That’s option two.

The product brochure offers an example. It hypothesizes a 58-year-old woman who makes a $100,000 contract payment. She plans to retire at age 65. Allianz Life immediately raises her PIV to $110,000 with a 10% purchase bonus.

In her first year of ownership, she earns 4%. If she has chosen option one, her PIV goes up by 10% and her account value goes up 2%. If she has chosen option two, her PIV goes up by 6% and her account value goes up 4%.

When she reaches age 65, her PIV has grown to a projected $186,000 or so. At that age, her age-adjusted payout percentage is 3.75%. She’s entitled to about $7,000 a year for life. That income can go up if she earns additional interest from the fixed indexed annuity, which keeps on going even after income begins. If for some reason she needs nursing home care, she could double her annual rate of withdrawal under the contract’s Alliance Income Multiplier benefit. Future annual withdrawals will be substantially lower, however.

The contract is complex, to be sure. Part of the complexity comes from the flexibility. The product can be used for accumulation or income. Liquidity is available but limited by the surrender fee, which starts at 9.3% in the first year and declines to 1.05% in the tenth year. The bonuses need to be weighed against the low payout percentages, which reach no higher than 4.75% for a single contract owner age 80 or more.

Part of the complexity also stems from the fact that the “planning process”—the kind of planning that a fee-based or fee-only adviser might provide to a client—is pre-baked into the product and lasts for the life of the client. The adviser or agent who sells an annuity contract is getting paid a commission by the issuer for distribution services, not necessarily for giving advice.

To use an analogy from the Internet world, buying an indexed annuity with lots of complex flexibility is like buying software as a service (SaaS). SaaS products often give their subscribers a lot of cloud-based functionality but rely largely on the subscriber to run it. There’s telephone or chat support after the sale, but the value of the product depends a lot on the subscriber’s own capability and perseverance.

Few fee-only advisers would sell a product like this, even if it were available on a no-commission basis. They earn asset-based, hourly, or by-the-project fees for offering guidance, not products. If they were looking for a scalable way to help mass affluent clients, such a product might fit into their practices.

But it probably wouldn’t suit their personalities. Fee-only advisers tend to regard annuities and other packaged products the way master woodworkers regard ready-made retail furniture. They’re certain they could produce something better and cheaper on their own workbenches.

But the larger point here is that low interest rates—which have lasted for years and could last for many more—send players in different niches of the retirement business in different directions toward different solutions for different types of customers. For life insurers who manufacture indexed annuities, bonus contracts like Allianz Benefit Control make the most sense.

© 2020 RIJ Publishing LLC. All rights reserved.

Yes, I Finally Bought an Annuity

Posted on March 5, 2020 by -

Last week’s market bungee-jump told me that my wife and I were right to buy an income annuity in late 2018. We bought a deferred period-certain contract that will deliver monthly income for our first 10 years of retirement.

By luck, we bought it before the 2019 rate cuts. Added to Social Security, it will cover our basic expenses. Our other savings is in stock funds, balanced funds, my wife’s small TIAA annuity, or cash. Annuity experts may groan at our decision. We bought “an expensive bond ladder.” We got no “mortality credits.”

But my wife is six years younger than I am. The payout from a joint life annuity looked unattractive. And she rejected any solution that jeopardized our heirs. The term-contract also gave us the nominal monthly income we needed for the portion of savings that we were prepared to spend on it. (The deferral period helped close the gap.)

Yes, we “discounted” our chances of living too long; but future equity gains might allow us to buy more years of safe income. (We hope.) As a backup, we have home equity and three daughters. Deciding to buy the contract wasn’t easy. Maybe it wasn’t even rational. But we feel relieved. We don’t sweat these short-term market slides.

© 2020 RIJ Publishing LLC. All rights reserved.

“Buffered” ETFs for sensitive stomachs

Posted on March 5, 2020 by -

Jittery investors don’t necessarily have to use index-linked annuities or structured notes to get protected equity exposure based on the purchase of options. They can use exchange-traded funds, or ETFs.

Since August 2018, Innovator Capital Management LLC, with subadvisor Milliman, has been issuing one-year ETFs that deliver returns between an upside cap and a downside buffer, with a choice of exposure to five different indices.

So far, Innovator has issued 41 one-year buffered ETFs. The funds now have about $2 billion in assets under management, Innovator CEO Bruce Bond said in a release this week.

The latest offering, the March Series of Innovator S&P 500 Buffer ETFs, started trading on the Cboe (Chicago Board Options Exchange) on March 2, Innovator Capital announced this week.

Like structured annuities (aka registered index-linked annuities or RILAs), the Defined Outcome ETFs use options to generate a customized range of returns based on the movement of an equity index. Investors can earn up to a capped return, while downside “buffer” zones limit their exposure to loss.

The products’ buffers, like airbags in cars, are designed to give retail investors a sense of safety—enough to prevent them from bailing out of equities during rocky markets. The ETFs give investors “defined exposures on broad benchmark indexes, where the downside buffer level, upside growth potential, and outcome period are all known, prior to investing,” the release said.

Each fund in the series has an annual management fee of 0.79%. Exposures to the S&P 500, NASDAQ 100, Russell 2000, MSCI EAFE, or MSCI EM indices are available. Investors can get protection from the first 9% of losses, or the first 15% of losses, and any losses between 5% and 35% over the one-year investment period. The upside caps for each fund are fixed when it is issued.

Like all ETFs, funds in the Innovator series trade throughout the day on an exchange. They’re more liquid than structured notes, Innovator said. Investors can buy into a one-year fund after its launch date, and they can roll their investment over for another year at the end of each “outcome period.” The original buffers and caps are likely to have changed, however.

A tool at the Innovator website shows where the ETF stands at any given time and what the current crediting terms are. The ETFs reset annually and can be held indefinitely.

Crediting formulas for the March Series of Innovator S&P 500 Buffer ETFs, as of 3/2/20 were:

*The caps above are shown gross of the 0.79% management fee. “Cap” refers to the maximum potential return, before fees and expenses and any shareholder transaction fees and any extraordinary expenses, if held over the full Outcome Period.

According to Innovator, each ETF holds custom exchange-traded FLEX Options with varying strike prices (the price at which the option purchaser can buy or sell the security, at the expiration date), and the same expiration date (approximately one year).

The layering of the FLEX Options with varying strike prices provides the mechanism for producing a Fund’s range of outcomes (i.e., the cap or buffer). Each fund intends to rollover options components annually, on the last business day of the month associated with each Fund.

Milliman Financial Risk Management LLC (Milliman FRM), the subadviser of the ETFs, also helped design the Cboe S&P 500 Target Outcome Indexes. The Innovator Defined Outcome S&P 500 Buffer ETFs are benchmarked against them.

© 2020 RIJ Publishing LLC. All rights reserved.

At These Rates, Why Bother to Save?

Posted on March 5, 2020 by -

Responding to last week’s stock market plunge—when fear literally went viral—the Federal Reserve lowered its benchmark fed funds rate by 50 basis points. The central bank was signaling that investors should… what, exactly? Is the message:

  1. Remain calm and stay invested, because liquidity will remain cheap and abundant, or
  2. Don’t bother saving, because safe assets won’t yield enough to make delayed-gratification—the very essence of saving—attractive.

The answer may depend on how much you earn per year and what you think your retirement will be like. For people in households with incomes under $62,000 a year and below-average health, the answer is likely to be “2,” according to a new paper from Stanford University economist John Shoven and three of his top former students.

If people behave rationally, as classical economists assume, then they are bound to notice that the return on government bonds is now less than the inflation rate. They may therefore decide to spend freely in early retirement rather than save their money until later, when it will buy less and when they might not be able to enjoy it.

“We find that for many, perhaps most, people in the bottom half of the lifetime earnings distribution, it is optimal to spend out their retirement wealth well before death and to live on Social Security alone after that. Very low earners may find it optimal to not engage in retirement saving at all,” they wrote in “Can Low Retirement Savings Be Rationalized?” NBER Working Paper 26784, February 2020.

Shoven and his co-authors—Jason S. Scott, Sita N. Slavov of George Mason University and John G. Watson of Stanford—challenge at least two major assumptions about retirement planning. One is the life-cycle hypothesis, which says that people want their consumption to be fairly constant over their entire life-cycle. The second, which is related, is the idea that people will need to 65% to 85% of their pre-retirement income in retirement to avoid feeling a decline in living standard.

This might apply to affluent people, the paper says. But people for whom Social Security will replace a large percentage of their pre-retirement income, and who expect to rely on Medicaid if they live long enough to need long-term care, have more reason to behave like the grasshopper in Aesop’s fable than the ant.

John Shoven

“Today, the real rate of interest is negative,” Shoven told RIJ this week. “So if you set aside money today, you’ll be able to afford lower consumption in the future than today. There are significant consequences to this era that we’re living in. For many people, their return on savings is less than zero. Bank accounts pay a quarter of a percent. They’re basically offer a minus two percent yield.

“If you said today, ‘Boy, I want to consume $30,000 per year when I’m 80,’ you realize that with today’s low rates you’d have to save a lot more to have $30,000 when you’re 80,” Shoven told RIJ this week.

“You might say, with rates so low, I’ll change the tilt of consumption. You’ll take that trip to Europe at age 70. We’re saying that declining consumption during retirement can be attractive—given the market rewards for patience. You might feel differently than you did fifteen years ago when you could get 2.5% real return if you invested in safe assets. the safe real rate of return was 2.5%.”

Shoven was asked if conserving money against the fearful possibility of big medical bills in old age would be rational. “With respect to high medical expenses, particularly with the cost of long term care, it is so expensive that it’s difficult to provide for,” he told RIJ.

“Many people who need long-term care will be supported by Medicaid. They’ll get about the same level of care whether they go into care with $50,000 in savings or if they have zero.”

[For people in the bottom half of the income distribution], “any achievable goal will be so small compared to the size of the need, that they lose by hoarding. They say, ‘I could be frugal and save $50,000, or I could enjoy myself now.’” If you spend your last $50,000 on long-term care, “You’re basically helping Medicaid instead of yourself,” he added.

While there’s an old saying about saving for a rainy day, Shoven suspects that people feel little motivation to save for tomorrow if they believe they will be sick tomorrow and won’t feel like vacationing.

“A representative sample of individuals are asked to imagine there is an even chance that they are in good or poor health at age 80,” the paper said. “They are then asked to how they would allocate a $10,000 windfall between those two possibilities. Would they prefer to have all, most, some or none of the windfall in the healthy or unhealthy state? Of interest for our work is that the answers, while volatile, tended to allocate wealth between the unhealthy and healthy outcome at an approximately 1:2 ratio.” A healthy day is worth twice as much as a sick day.

It’s not likely, Shoven added, that low-income savers will respond to low yields by taking more risk. “The model says, ‘Declining consumption is optimal, given the way the market fails to reward delayed consumption,” he said. “In other words, whatever resources you have, you’ll spend more in your younger years.

“We don’t address the possibility that, in the face of extremely low interest rates, some people will say, ‘I’ll take more risk with my investments.’ We didn’t go into that. Typically, as people get older, they want to be in safe assets.”

If correct, this paper’s conclusions clash with more than one of the basic rules of thumb for retirement planning. The paper suggests that it doesn’t make much sense for people in the bottom half of the income distribution to defer Social Security benefits until age 70 or to buy life annuities.

“The considerations in this paper may help to explain the lack of demand for private annuities,” the authors wrote. “Spending liquid assets for annuities whose payout pattern does not correspond with optimal consumption isn’t particularly attractive. It is well known that private annuity markets suffer from adverse selection [the tendency for people with long life-expectancies to buy annuities]. Adding a sub-optimal pattern of payouts [with constant rather than declining consumption] further reduces the attractiveness of annuities, especially for those in the lower part of the income distribution.”

The paper’s reliance on the concept of homo economicus—the assumption that ordinary people think like economists—might raise the eyebrows of behavioral economists who believe that many people exhibit “irrationality” or “bounded rationality” when dealing with money.

“There could be a criticism of our approach in the sense that people might behave with rules of thumb rather than completely rationally,” Shoven conceded. “This is a rational approach. Like a lot of economists, we assume rationality on the part of the investor. The simple, rational model that economists use doesn’t argue for a constant standard of living as you age.”

© 2020 RIJ Publishing LLC. All rights reserved.

Project LIMA Aims to Solve the Annuity Puzzle

Posted on February 27, 2020 by -

Let’s assume that most American retirees would be better off with pensions. And let’s assume that most people who want a pension would have to buy it with part of their 401(k) savings. How then would you retrofit the 401(k) system to make that possible?

One new proposal is Project LIMA, or Lifetime Income Managed Accounts. This specific idea comes from the math laboratories of Milliman, the actuarial consulting firm whose risk-management algorithms are embedded in a wide range of mutual funds and annuities.

If a 401(k) plan sponsor adopted LIMA, a participant who has elected to use a managed account (as opposed to a target date fund) could apply a percentage of each payday contribution to the gradual purchase of a qualified lifetime annuity contract, or QLAC. In retirement, the QLAC would deliver inflation-adjusted monthly income for life.

We’re hearing about LIMA now because the SECURE Act finally passed. The Act makes it less likely that a participant might sue an employer over any adverse consequences of buying an in-plan annuity.  That includes QLACs inside managed accounts as well as target date funds with “guaranteed income riders.”

But legal liability hasn’t been the only reason that illiquid, life-contingent deferred income annuities haven’t taken up residence in 401(k)s (though they’ve long existed in 403b plans). The fund firms who provide investment options for 401(k) earn a percentage of assets under management, or AUM.

Until now, any money diverted into multi-premium annuities would disappear from AUM and from recordkeeping statements. One of the proposals within Project LIMA is that the annuity value stays in the managed account, shows up in recordkeeping statements, and is in turn part of AUM. Richter is hopeful that providing this substantiated valuation process for the annuity income stream will provide a basis for billing.

Michelle Richter

“Milliman’s contribution to the recipe, and it’s essential to the design, is the valuation and dynamic re-valuation of the annuity within the managed account,” said Michelle Richter, the Milliman consultant who is leading the Project LIMA effort.

“Providing this substantiation valuation process for the annuity income stream will provide a basis for billing,” she added. “We are starting from a ‘safety first’ perspective [i.e., aiming to generate enough guaranteed income through the annuity to cover basic retirement expenses] and ladder into guaranteed income across the rate environment. But there are a lot of ways that this could be implemented.”

Growing income gradually

In a hypothetical example offered by Milliman, a 40-year-old participant, Jane Doe, has a $50,000 DC plan balance. She plans to retire at age 67. She’s a conservative investor who has chosen a managed account over a target date fund, and an asset allocation of 50% stocks and 50% bonds.

Jane is offered the option of enrolling in a managed account with a QLAC. She fills out a questionnaire that will reveal her estimated basic expenses in retirement and how much more guaranteed income, above Social Security and pension, if any, she will require to cover those expenses. She then chooses either to start a) buying a QLAC that will meet her essential monthly retirement expenses, b) buying a QLAC with her employer’s matching contribution, or c) not buy a QLAC.

The LIMA algorithm determines that approximately 3% of her savings should be contributed to a QLAC each year. At the end of the first year, she’ll have $25,000 in stocks, $23,519 in bonds, and a QLAC with a book value of $1,481. Fast-forward 13 years: At age 53, Jane now has $123,632 in stocks, $69,894 in bonds, and a QLAC with a book value of $44,293.

During those 13 years, the adviser handling her managed account would have rebalanced her portfolio allocations back to her conservative risk level. The LIMA algorithms would also determine the amount of annuities Jane Doe needs to acquire over time to achieve her ‘Safety First’ income targets. As Richter envisions the process, Jane will have purchased pieces of QLAC from several different life insurance companies by then.

If Jane decides to leave her employer, she can roll over to a managed IRA provided, perhaps, by the same fund company that provided her 401(k) managed account. Somehow—and this part isn’t complete—her slivers of QLAC from different insurers would be resolved into a single payment. She would begin receiving income from the QLAC sometime between age 72 and age 85.

“Several insurers tell us they have capacity for and interest in QLACs, assuming that the distribution likes it. A lot of new recordkeeping work would have to be done to handle QLACs in-plan, as opposed to selling them as standalone products,” Richter said.

“To the extent that the QLACs are embedded in a managed account structure, it’s easier for the recordkeeper and the asset manager to handle, as opposed to managing separate assets,” she added. “Since SECURE passing, there has been more discussion about how annuities as retirement income solutions are expected to make their way into 401(k) plans, and we are excited about the potential of designs like Project LIMA.”

What’s old is new again

The efficiency (or “utility” in economics) of this concept was recognized long ago. Many have seen the wisdom of buying annuities incrementally instead of with lump sums and delaying payouts to age 80 or later, when each premium dollar buys the most income.

In 2004, Moshe Milevsky of York University proposed the Advanced Life Deferred Annuity, or ALDA. It was contingent on both life and exhaustion of a deductible. “A consumer can invest or allocate $1 per month… and receive between $20 and $40 per month in benefits, assuming the deductible in this insurance policy is set high enough,” he wrote.

Jason S. Scott, Ph.D., the current director of the Retiree Research Center at Financial Engines, wrote in 2007, “A new type of annuity, a longevity annuity, is optimal for retirees unwilling to fully annuitize. For a typical retiree, allocating 10%-15% of wealth to a longevity annuity creates spending benefits comparable to an immediate annuity allocation of 60% or more.” But in 2011, when Financial Engines launched its managed account income-generation tool, Income+, automatic annuitization of assets was not in the design.

In 2008, six months before the financial crisis, MetLife and Barclays Global Investors collaborated on an ambitious but never-launched 401(k) program called SponsorMatch. Participants would apply their employers’ matching contributions to purchases of future income. That same year, MassMutual and entrepreneur Jerry Golden experimented with a rollover IRA product, the Retirement Management Account, which turned qualified retirement savings into income.

CANNEX, the provider of annuity data and comparative analysis tools, has been working for years on the problem of valuing income annuities so that they fit better into advisers’ AUM business models. Some of its technology might find its way into LIMA.

“We’ve been waiting for something to change in the industry to facilitate quotes in this area. The SECURE Act helps considerably,” Tamiko Toland, head of Annuity Research at CANNEX USA, told RIJ.

Several big retirement plan providers, such as Prudential and Empower, have already approached the in-plan annuity challenge, but from a different angle. They’ve offered target date funds with lifetime income riders as a 401(k) investment option. Their products are called IncomeFlex and SecureFoundation, respectively.

Unlike QLACs, these riders offer participants liquidity and a guarantee that, if their own account hits zero before they die (and they have obeyed the contractual limits on annual withdrawals), the insurer will continue making their monthly annuity payments as long as they live. Such contracts offer life insurers an attractive combination of high fee income with low risk exposure.

But sales of that TDF-based product have been low, in part because most plan sponsors hesitate to put their participants’ nest eggs in one life insurer’s basket. (Connecticut-based United Technologies Corp. solved that problem by using three living benefit providers that compete through a bidding process.) Richter is hopeful that multiple insurers will want to participate in Project LIMA.

“We started to quietly investigate the premise of the LIMA project back in the fall, with some reasonable industry interest,” Richter told RIJ. “We’re talking with a number of organizations spanning the asset management, recordkeeping and insurance industries. More than one version of what we’re imagining would require all of those three communities’ joint collaboration.”

© 2020 RIJ Publishing LLC. All rights reserved.

Investors pump money into bonds: Morningstar

Posted on February 27, 2020 by -

Long-term mutual funds and exchange-traded funds gathered $82.8 billion in January—their best month since January 2018. But the mix of recipients has shifted in two years. In January 2018, 46% of inflows went to U.S. and international equity funds; in January 2020, however, those two categories combined suffered net outflows, according to the monthly fund flow report from Morningstar Research.

Instead, investors pumped money into fixed-income funds last month. The taxable-bond group took in a record $63.6 billion, topping the previous record of $50.5 billion set only one month prior. Those flows accounted for almost 77% of all long-term fund inflows in January.

The strong January marked 13 straight months of inflows into taxable-bond funds. Both actively and passively managed funds in the category benefited. Actively managed taxable-bond funds raked in $36.9 billion in January, their best showing since September 2009. Their passively managed counterparts added $26.7 billion.

Within the taxable-bond space, investors took interest in core strategies focused mostly on investment-grade securities. Intermediate core-bond funds gathered $17.3 billion for the month, just shy of the $17.4 billion record reached in January 2018. The intermediate core-plus category’s $12.7 billion of inflows was a record, beating the old mark of $10.9 billion set in December 2019.

Records fell for municipal-bond funds, too, as investors continued to hunt for sources of tax-free income. With $14.1 billion in January inflows, they blew past the previous mark of $11.2 billion set in February 2019. Prior to that, the last time muni flows hit $11 billion in a month was in September 2009 as the U.S. began to recover from the global financial crisis. Funds in the muni national intermediate category fared the best, pulling in $5.2 billion in January. That built upon a solid 2019, when the category led all muni cohorts in total flows.

Meanwhile, U.S. equity funds had their worst month since February 2018, suffering $22.5 billion of outflows. Some of this is likely due to portfolio rebalancing after a strong 2019 for U.S. equities overall. Actively managed funds felt the most pain. More than $30 billion flowed out of those products; conversely, passive options netted $7.9 billion.

International equity funds were a bright spot, taking in $18.7 billion—their best month of inflows since February 2018. On a net basis, all the money went to passively managed funds. They garnered $20 billion in January while their active colleagues saw $1.2 billion in net redemptions. Investors generally sought broad exposure to international equities. Vanguard Total International Stock Index was a top recipient of passive-product inflows, amassing $4.8 billion during the month.

Among equity categories, U.S. large-growth funds had their third-worst outflows—$9 billion—since the start of 2017. Investors’ money has been exiting that style-box segment for a while now. The category has had net redemptions every calendar year since 2004. Though its total net assets grew by nearly 137% to $1.9 trillion over that 16-year period, the outflows whittled large-growth funds’ share of the open-end/ETF universe from 16% in early 2004 to only 9% in January 2020.

© 2020 Morningstar, Inc.

Interpreting SEC’s new ‘principles-based’ advertising rule: Wagner Law Group

Posted on February 27, 2020 by -

In early November 2019, the Securities and Exchange Commission (SEC) released proposed amendments to the advertising rule and solicitation rule under the Investment Advisers Act of 1940 (“Advisers Act”), Rules 206(4)-1 and 206(4)-3, respectively.

The proposed amendments attempt to modernize the rules to reflect technological changes, today’s investor expectations, and current industry practices. Over the years, both rules have been interpreted and supplemented via no-action letters and other guidance.

The relevant letters and guidance are listed in the SEC’s release and they will be reviewed to determine whether any should be withdrawn in connection with the adoption of the proposed amendments, which shift the rules’ existing “specified limitations” approach to a more flexible so-called “principles-based” approach.

Given the broad scope of the proposal, and the potential for a significant increased effort by chief compliance officers to comply with the changes, we will address a few elements of the advertising rule proposal below, and discuss the solicitation rule in a subsequent Investment Management Law Alert.

Amendment to Advertising Rule

The advertising rule should be understood against the backdrop of the anti-fraud rule. Section 206 of the Advisers Act makes it unlawful for any investment adviser, whether registered or unregistered, to directly or indirectly engage in any act, practice, or course of business that is fraudulent, deceptive, or manipulative. Advisers have an affirmative obligation of utmost good faith and full and fair disclosure of all material facts to their clients, as well as a duty to avoid misleading them. A financial adviser’s “intent to deceive” is not relevant per se and is not required by the language of the Advisers Act.

The rule is broad and applies to all firms and persons meeting the Advisers Act’s definition of investment adviser, whether registered with the SEC, a state securities authority, or not at all. It also applies to all written correspondence, not just to advertisements. Section 206(4) of the Advisers Act grants the SEC authority to define acts that are fraudulent and to prescribe means reasonably designed to prevent fraud.

Definition of advertisement. First, the proposed amendment would change and broaden the definition of “advertisement.” The SEC views the current definition in Rule 206(4)-1(b) as inflexible and proposes a new definition that is intended to be more “evergreen” in light of ever-changing technology.

The proposed amendment would redefine “advertisement” to include any communication disseminated by any means, by or on behalf of an investment adviser that offers or promotes investment advisory services or that seeks to obtain or retain advisory clients or investors in any pooled investment vehicle advised by the adviser.

The proposed “dissemination by any means” language would change the scope of the rule to cover all promotional communications, which would better focus the rule on the goal of the communication, rather than on its method of delivery. The proposed “by or on behalf of the investment adviser” language would cover advertisements disseminated by an adviser’s intermediary.

The amendment proposes to exclude the following from the definition of “advertisement”:

(1) Live oral communications that are not broadcast;

(2) Responses to certain unsolicited requests for specified information;

(3) Advertisements, other sales material, or sales literature that is about a registered investment company or a business development company and is within the scope of other SEC rules; and

(4) Information required to be contained in a statutory or regulatory notice.

Observations:

  • Excluded communications may not relate to performance or hypothetical performance information.
  • Must consider communications authorized by adviser to be made by third-party intermediaries, as well as affiliates.
  • Specifically applies to investors in pooled investment funds.
  • Replaces “written” communications with “any communication, disseminated by any means.”

Testimonials, endorsement and third-party ratings permitted. The advertising rule has four specific prohibitions (hence, the “specified limitations” approach) and one “catch-all” provision.

Advertisements that refer, directly or indirectly, to any testimonial concerning the adviser or any advice, analysis, report, or other service rendered by the adviser, is one of the four prohibitions.

The proposed amendment would permit the use of testimonials, endorsements, and third-party rankings in advertisements, subject to specific disclosures including whether the person providing the endorsement is a client, whether compensation was paid for the endorsement, and certain criteria pertaining to the preparation of the rating.

Observations:

  • The SEC is addressing the ability of technology platforms that allow instantaneous sharing of testimonials and endorsements.
  • Must disclose both cash and non-cash compensation provided by or on behalf of the adviser, but does not define any definition to the term “non-cash compensation” nor does it have a threshold amount.
  • SEC is attempting to protect the integrity of third-party ratings by requiring that the adviser reasonably believe that any questionnaire or survey used in preparing such third-party rating is structured so that it is equally easy for a participant to provide both favorable and unfavorable responses.

Performance reporting and retail investors. The Advisers Act and underlying rules do not contain any direct prohibition concerning the use of performance data in advertising, nor does it articulate a prescribed method by which past performance must be calculated. Rather the calculus turns on whether the advertising of performance is false or misleading, based on a “facts and circumstances” approach.

Under this approach, the use of performance results is false or misleading if it implies, or a reader would infer from it, something about the adviser’s competence or about future investment results that would not be true had the advertisement included all material facts. The proposed amendment would permit the use of performance advertising with some specific prohibitions. The investment advisor must meet more rigorous requirements when the intended audience is a retail investor.

Observations:

The proposal makes a distinction between retail and non-retail advertising. In simple terms, a non-retail advertisement is distributed to a “qualified purchaser,” or a “knowledgeable employee,” and a retail advertisement is all other advertisements that are not “non-retail.”

The proposal identifies numerous classes of performance data: net, gross, related, extracted, and hypothetical. Ported performance is not directly covered in the proposal.

The proposal addresses other areas of advertisements:

It would require a rigorous pre-review and compliance approval by a designated person, who the SEC indicates should be competent and knowledgeable, and should reside in the compliance or legal department. Comments are invited as to whether an outside party could perform the requisite review.

Certain communications to a single person or private fund investor, and live oral communications that are broadcast over TV or the Internet would be exempt from pre-review.

The proposal would also amend the books and records requirements under Rule 204-2 to create and maintain specified communications, third-party questionnaires and surveys, and records that evidence the pre-review process.

© 2020 Wagner Law Group.

Lifetime income withdrawals from FIAs up 39%: Ruark

Posted on February 27, 2020 by -

Ruark Consulting, LLC has released the results of its 2020 industry studies of fixed indexed annuity (FIA) policyholder behavior, which include surrenders, income utilization and partial withdrawals. Ruark’s FIA studies cover products both with and without a guaranteed lifetime income benefit (GLIB).

“With new data contributors, and rapid growth in the FIA market, data exposures in key areas continue to increase,” said Timothy Paris, Ruark’s CEO. “More data enables us to do more detailed analysis, identify new patterns, and—critically—help our clients achieve meaningful risk reduction in their models.”

Among the notable increases in exposure:

  • Total exposure years grew to 23 million, a 21% increase over the 2019 study
  • Double the exposure years for GLIB contracts past the end of the surrender charge period
  • A 39% increase in lifetime income withdrawals, to $5.4 billion
  • The study data comprised over 4 million policyholders from 17 participating companies spanning the 12-year period from 2007-2019, with $296 billion in account value as of the end of the period. GLIB exposure constituted 44% of exposure overall, and 49% of exposure in the last 12 study months.

Highlights include:

Lifetime income commencement rates are low: 6% overall in the first year following the end of the waiting period and then falling to less than half that subsequently. But there is evidence of a spike in commencement after year 10, particularly where the benefit is structured as an optional rider rather an embedded product feature. Age, tax status, and contract size all influence commencement rates.

Lifetime income commencement increases sharply when policies are in the money, that is, when the benefit base exceeds the account value. After normalizing for age, tax status, and contract duration, commencement rates are about five times higher for contracts that are 25% in the money or more.

Surrender rates continued to climb in 2019, particularly among contracts past the surrender charge period. The increase is broadly consistent with the rise in FIA sales that has been reported across the industry. This trend is also evident for contracts with a GLIB, where surrenders rates are much lower, particularly after lifetime income commencement.

While surrender rates for contracts with a GLIB appear insensitive to nominal moneyness (the relationship of account value to the benefit base), an actuarial moneyness basis which discounts guaranteed income for interest and mortality rates indicates surrender rates are lower when the economic value is higher, as should be expected.

The relationship between higher surrender charges and lower surrender rates can be quantified. The study examined the relationship of surrender rates to the effective surrender charge, that is, the difference between account value and cash surrender value, which includes the potential effects of market value adjustment (MVA) and bonus recapture.

Surrender rates are sensitive to credited rates and external market pressures. Contracts earning less than 2% exhibit sharply higher surrenders than those earning more. As market interest rates increase, so do surrenders, though there is some indication that a higher credited rate tempers the increase. In contrast, equity market returns are negatively correlated with surrenders.

Detailed study results, including company-level analytics, benchmarking, and customized behavioral assumption models calibrated to the study data, are available for purchase by participating companies.

Ruark Consulting, LLC (www.ruark.co), based in Simsbury, CT, is an actuarial consulting firm. It provides a platform and industry benchmark for principles-based insurance data analytics and risk management. Ruark has an ongoing collaboration with the Goldenson Center for Actuarial Research at the University of Connecticut.

© 2020 RIJ Publishing LLC. All rights reserved.

Why Bernie is So Demanding

Posted on February 27, 2020 by -

If Bernie Sanders, the left-of-center senator from Vermont, becomes the Blue candidate for president, expect political dirt like you’ve never seen. But underneath the mud and memes, behind the deepfakes and denials, we may witness a legitimate debate over the relative merits (and demerits) of supply-side and demand-side economics.

Supply-side economists believe that if you lower taxes and cut regulations, entrepreneurs will be unleashed to create new businesses, hire more workers, produce more stuff, and even generate more tax revenue for government.

Supply-siders have been in the macroeconomic saddle for the past 40 years. The word “saddle” is apt: the concept roared out of the American West. Arthur Laffer (who advised Donald Trump in 2016) was its premier economist. Journalist Jude Wanniski popularized the term “supply-side” and published a 1978 book about it. Ronald Reagan implemented it, more or less. After the “stag-flation” of the 1970s, supply-side economics blew in like a refreshing zephyr.

And many people became gloriously rich as a result. The early 1980s saw the start of the longest bull market, in both stocks and bonds, that the universe had ever seen. Though factories went dark, the deregulated financial and tech sectors flourished. The fact that tens of millions of baby-boomers were working, saving, buying homes and procreating didn’t hurt.

Wage deflation

But today, there are signs that the supply-side miracle has run its course. Boomers are retiring. Interest rates have no room left to fall. Tax cuts have added to unprecedented deficits. Homes and financial assets are priced to the max. The financial crisis showed that deregulation has a downside.

Supply-side economics brought, or coincided with, rising inequality. America gradually divided into two camps: A minority with large amounts of appreciated assets, like homes and securities, and a majority with few or no assets that appreciate. The ever-widening gap between haves and have-nots is well-documented.

As the Pew Research Center reported this month, national income is concentrated among fewer people. Eighty percent of Americans now receive only 43% of national income, down from 56% in 1968. Instead of inflation (the bane of creditors), we’ve seen wage deflation (the bane of debtors). Consumer prices have almost doubled since 1990, but wages have grown only 26.5%. We’re at full employment, but the civilian labor force participation rate is lower than it was in 2000.

This creeping poverty, linked to globalization, shows up in the falling life expectancies of rural white workers with less than college educations. Unable to earn adequate pay, many don’t marry, form families or set up households. Frustrated by their failure to meet their own and society’s expectations, they become prey to OxyContin, heroin and anger. Once proudly self-reliant, they welcome someone to blame.

The president rode to victory on that wave of anger, and on promises to reopen coal mines and steel mills. Instead, he lowered taxes and interest rates, which was good for stocks. But that hasn’t helped people whose income and taxes are already low, who pay double-digit interest rates on credit cards, and who own few if any equities.

Another turning point

Bernie Sanders

Hence the return of demand-side economics. Also known as post-Keynesian economics or the (much maligned and misunderstood) Modern Monetary Theory, demand-side economics held sway from 1932 until 1971, when Richard Nixon abandoned the gold standard. Bernie Sanders is its atavistic avatar.

Demand-side is the flip-side of supply-side. Supply-siders and other neoclassical economists believe, for instance, that a higher minimum wage will lead to higher prices, layoffs, and a slowdown. Demand-siders and other “heterodox” economists believe that higher wages will lead to higher demand, more production, and more employment. They insist that less inequality means more prosperity for everybody, even the rich.

So if you hear Sanders fulminate about universal health care or free college, think “demand-side” economics. He’s addressing the same malaise that Trump exploited, but with a bottom-up solution that’s been out of favor for more than 40 years. Supply-side economics has been so dominant for so long, in fact, that you almost have to be Bernie’s age to remember that demand-siders once ruled the field.

© 2020 RIJ Publishing LLC. All rights reserved.

NAIC approves revised “best interest” rule for annuities

Posted on February 20, 2020 by -

In a meeting of the National Association of Insurance Commissioner (NAIC) Plenary last week, the association approved revisions to the Suitability in Annuity Transactions Model Regulation (#275), a February 13, 2020, NAIC release said.

The revisions clarify that all recommendations by agents and insurers must be in the best interest of the consumer and that agents and carriers may not place their financial interest ahead of in the consumer’s interest in making the recommendation. The model now requires agents and carriers act with “reasonable diligence, care and skill” in making recommendations.

“These changes underscore the commitment of U.S. insurance regulators to protecting consumers purchasing annuities,” said Ray Farmer, NAIC President and South Carolina Insurance Director. “Nearly every state has adopted the model, which has been protecting consumers for 15 years. I encourage my colleagues to work with their state legislatures to pass these updates to provide even stronger protection.”

The revisions incorporate a “best interest” standard into the model revisions that require producers and insurers to satisfy requirements outlined in a care obligation, a disclosure obligation, a conflict of interest obligation, and a documentation obligation. The model revisions also include enhancements to the current model’s supervision system to assist in compliance.

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