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LGPS Investment Pooling: Next Steps
December 2015
LGPS Investment Pooling: Next Steps
John Wright
Head of LGPS
The Chancellor’s Autumn Statement contained some long awaited detail on
the government’s proposals for the reform of the approach to the investment
of LGPS assets in England and Wales. Much of what emerged was as
expected but as ever the ‘devil is in the detail’ and there is a lot of detail
buried in the many documents that were published alongside the statement.
The purpose of this note is to help you understand the implications of the
proposed changes and plan what you need to do in the coming weeks and
months to respond to the requirement to pool investments. In addition there
is a consultation on modernisation of investment regulations which will also
facilitate pooling – this requires a response by 19 February 2016.
Criteria for pooling of assets – not subject to consultation
The document entitled Local Government Pension Scheme: Investment Reform Criteria and
Guidance 1 sets out the criteria that will be applied to proposals for the pooling of assets;
Linda Selman
Head of LGPS
Investment
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Achieve the benefits of scale – up to 6 asset pools of £25bn or more
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Strong governance and decision-making – investments should be managed
appropriately by the pool with risk adequately assessed and managed. The pool
should have appropriate resources and skills. Local authority will hold the pool to
account.
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Reduced costs and excellent value for money – pools need to deliver substantial
savings in investment fees, both in the near term and over the next 15 years while at
least maintaining investment performance.
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An improved capacity to invest in infrastructure – proposals should show how the
pooling arrangements will enable the funds to invest more in infrastructure
These criteria are very much as expected given the discussions that have taken place with
Treasury and DCLG since the first announcement of pooling in the Summer Budget. We set
out below the key messages relating to pooling.
1
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/479925/criteria_and_g
uidance_for_investment_reform.pdf
Briefing Note 01
LGPS Investment Pooling: Next Steps
Timetable and Proposals to government
By 19 February 2016 you must submit your initial proposals to government including your
commitment to pooling, describing your ‘progress towards formalising arrangements with
other authorities’. These submissions can be individual or joint, or both.
By 15 July you must make your final submission which fully addresses the criteria set out
above, with enough information for the proposal to be evaluated by government. Each pool
must make a submission which covers the joint proposals and describes the proposed
governance, structure and implementation plan. Each authority must submit an individual
return which sets out the profile of costs and savings, the transition profile for the assets and
the rationale for any assets which it proposes to hold outside the pool.
Impact of pooling on your investment strategy, manager selection and implementation
The guidance published alongside the criteria gives more detail on how the government
expects pooling to operate. Aspects covered include the following:
Asset allocation
Strategic asset allocation, described as the balance between bonds and equities, will remain
a local decision for the administering authority and pensions committee. However, there
seems to be some flexibility in relation to more granular strategy decisions in that each pool
will decide what asset allocation decisions will be taken by the pool (and, by implication,
which will be taken locally at individual fund level) with the proviso that the pool has to deliver
value for money. We interpret this as meaning that the pool will decide, in consultation with
the participating authorities, which decisions are made where and the range of asset choices
the pool will offer. There are details for funds to consider in their proposals including how
decisions will be made in areas such as different choices for listed equity investment (UK,
non-UK, manager style, active or passive), different approaches to the investment in bonds
(traditional benchmarked approaches, multi-credit, absolute return) and the choice of external
versus in-house investment if both are available in the same pool.
Manager selection
There is a very emphatic statement that ‘manager selection will need to be undertaken at
pool level’. The expectation is that this will rationalise the number of managers used leading
to lower investment fees.
Specific asset classes and approaches
Active vs Passive Management
The extent to which each authority or pool uses passive management will remain their own
decision but the balance between active and passive should be kept under review to ensure
that active management is delivering value for money.
Property
Some existing property assets (for example, directly held property investments) may be kept
out of the pools and managed directly. New allocations should be pooled to take advantage
of the potential to share costs.
Infrastructure
Authorities need to consider how they might get more direct access to infrastructure using the
benefits of scale. They need to indicate how much they expect to be able to allocate to
infrastructure in the future.
Briefing Note 02
LGPS Investment Pooling: Next Steps
Investing outside the pool
A number of funds have been concerned about what happens to their local investments and
other special cases. There needs to be a clear rationale for any assets that are to be held
outside the pool. The expectation is that these will form a small proportion of the total assets
and will be confined to existing investments.
In-house management
The government acknowledges that internally managed funds can already show very low
management costs but those funds will not be exempt from pooling. The government points
to the wider benefits of collaboration and mentions two possible models: a pool of internally
managed assets with additional opportunities for reducing costs and increasing expertise and
resilience or, alternatively, a model with newly created pools working with existing in-house
teams.
Responsible investment and ESG
The government does not intend to amend the existing principles on social, environmental or
corporate governance considerations and some guidance will be issued to clarify how these
considerations may be reflected in investment strategy; policies should reflect the liability
profile of the LGPS and ‘enhance the authority’s ability to manage down any funding deficit
and ensure that pensions can be paid when due.’
Proposed changes to investment regulations – subject to consultation
The Investment Regulations and the backstop legislation are both subject to consultation, set
out in Local Government Pension Scheme: Revoking and replacing the Local Government
Pension Scheme (Management and Investment of Funds) Regulations 2009 2. This
consultation applies to England and Wales and closes on 19 February 2016.
Investment Regulations
The government has proposed the removal of Schedule 1 to the existing regulations which
sets out specific limits on investments. The specific limits will be replaced by a prudential
approach. Each fund will be required to set out an ‘investment strategy statement’ which will
in effect replace the current Statement of Investment Principles. The statement will be
required to address risk, diversification, corporate governance, responsible investment and
the authority’s approach to pooling.
The first investment strategy statement must be published no later than six months after the
regulations come into force (by 1 October 2016 if the regulations take effect on 1 April). For
the interim period between 1 April (or whatever date is applicable) and the publishing of the
statement specific regulations, the relevant existing regulations, including Schedule 1, will
remain in effect.
We welcome the move to a prudential approach; our response to the consultation in 2011
proposed that change.
2
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/479642/Consultation_on_inve
stment_reform.pdf
Briefing Note 03
LGPS Investment Pooling: Next Steps
Power of intervention (‘backstop legislation’)
We had been promised some ‘backstop legislation’ to deal with any authority which did not
come forward with sufficiently ambitious plans to pool their investments. Draft regulation 8 in
the proposed new investment regulations provides for the Secretary of State to intervene if an
authority is
 Ignoring best practice
 Is not following guidance, including not participating in one of the large asset pools or
proposing a pooling arrangement that does not meet the criteria set out above
 Carrying out another pension-related function poorly
Draft regulation 8(2) describes the interventions the Secretary of State may make, including
 Requiring the development of a new investment strategy
 Directing the investment of the assets to adhere to the criteria and guidance
 Directing the implementation of the investment strategy to be undertaken by another body.
What you need to do next
All funds need to do the following:
1) Form a view on your preferred approach to pooling (what you will do) – an
approach that meets your needs and government objectives. In forming a view you
may find it useful to draw on the work of the local authorities participating in Project
POOL 3 which is considering the best ways of accessing different asset types and
different pooling models. In addition, many funds are already at various stages of
discussion with other local authorities on ideas for collaboration and pooling.
2) Prepare a response to government with your initial proposals on pooling by 19
February 2016 - you may choose to do this as an individual authority or as a group
of local authorities working on specific pooling proposals. The priority should be to
consider what you propose to do and “demonstrate progress towards finalising
arrangements” - it is not essential to finalise who you will pool with by that date (you
have until the second stage deadline in July 2016 to finalise who you will pool with);
3) Respond to the government consultation on changes to the Investment Regulations
including back-stop legislation – again this needs to be done by 19 February 2016.
You will also need to start planning for the second stage deadline for proposals for pooling
(15 July 2016). This is not a trivial task. As well as finding like-minded partners for
collaboration, you will need additional data and analysis to inform your proposals and well
thought out and presented proposals to ensure a favourable response from government.
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Project POOL is being supported and project managed by Hymans, and involves collaboration across 25 fully participating funds and
support and expertise from a number of other funds. Please call your usual contact at Hymans for further details.
Briefing Note 04
LGPS Investment Pooling: Next Steps
In the short term, there is a significant communication exercise to complete with your
Committee in order to help the Elected Members understand what government expects of
the LGPS.
Longer term, the next two or three years will be very demanding; current investment
arrangements will still need to be monitored and maintained while plans are made for
collectivising assets. Professional project management will be key to managing what is a
massive change programme, otherwise there is a risk that the cost of change undermines
the potential savings. Some funds may need additional resources to manage the change.
Please speak to your usual Hymans contact to explore how we can support you, both in the
short and long term.
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