Because the mud settled on September’s pension scheme disaster, John Ralfe, a pensions specialist and early proponent of liability-matching funding methods, didn’t hesitate to pick out his goal.
Funding consultants have been the “villains of the piece”, he informed MPs in November, having advocated merchandise that constructed up hidden leverage within the system and sparked a market disaster within the wake of former prime minister Liz Truss’s “mini Finances”.
“They’re all about pushing complicated, costly merchandise of 1 type or one other,” Ralfe stated. “And the product they’ve been pushing for the previous few years has been leveraged LDI.”
Legal responsibility-driven funding requires pension funds to focus not on asset progress however on monitoring liabilities — the current worth of the pensions they’ve promised to pay out in future. It includes heavy purchases of presidency bonds but additionally the deployment of leverage, or borrowing, in the usage of devices corresponding to gilt repurchase agreements, or repos.
When long-term gilt yields shot up following the “mini Finances”, pension schemes’ LDI hedges got here unmoored, forcing them to dump lots of of billions in belongings to fulfill collateral calls in a sell-off that solely abated when the Financial institution of England intervened within the bond market.
Institutional funding consultants intermediate greater than $25tn in belongings globally, in accordance with the UK’s Monetary Conduct Authority. Within the UK, the pension advisor trade is each massively influential and significantly concentrated, but its funding recommendation to trustees shouldn’t be presently regulated.
The highest three consulting corporations — Aon, Mercer and Willis Towers Watson — management as much as 80 per cent of the UK advisory market based mostly on proportion of consumer belongings, in accordance with 2017 estimates from the FCA that trade consultants don’t consider have shifted a lot since. For outlined profit pension schemes, the a part of the market that received into bother, the proportion might be increased.
“The funding advisor is fairly basic to DB pension funds within the UK,” stated one supervisor who works with pension shoppers at a significant asset supervisor. “Only a few trustee boards go in opposition to their recommendation. They’re very a lot a gatekeeper to the consumer.”
Calls to manage the pension consulting trade extra carefully have gained traction for the reason that LDI disaster after a earlier try and carry it below the FCA’s remit faltered in the course of the pandemic regardless of gaining broad help from buyers, trustees and the main consultancies.
“Maybe if [pension fund] advisers had been extra delicate to coping with ranges of stress like this, a few of that danger would have been managed extra successfully,” FCA boss Nikhil Rathi informed a parliamentary committee in November.
Nevertheless, he added that “I wouldn’t go as far as saying that, in and of itself, would have prevented such a state of affairs.”
Focus within the recommendation market is a key concern for regulators, though opponents to the massive three — together with Lane, Clark & Peacock and Redington — have gained market share in recent times. The rise {of professional} trustees at UK pension schemes can also be thought to supply some ballast to the dominance of advisor recommendation.
“The recommendation given to schemes was very comparable throughout the board . . . and since all of them did the identical factor, it resulted in a systemic drawback,” stated Toby Nangle, an unbiased analyst.
However Nangle doubts whether or not extra complicated merchandise have been favoured by consultants for their very own sake. “Schemes have used leverage to unravel accounting and regulatory issues,” he stated. “If everybody may do it with out leverage, they might.”
The sway consultants maintain over the UK market is basically on account of particularities of the regulatory regime, which calls for a give attention to schemes’ funding ranges, and accountancy requirements launched within the Nineteen Nineties that compelled corporations to place their pension deficits on to their steadiness sheets.
An trade sprang up round advising pensions on how greatest to handle these liabilities, and LDI grew to become a preferred resolution. By 2022, UK outlined profit pension scheme liabilities had grown to about £1.8tn, in accordance with LCP, 85 per cent of which was hedged utilizing LDI.
The Competitions and Markets Authority introduced a lot of new measures in 2018 to allay trade issues over governance, requiring trustees to run tendering processes on fiduciary administration preparations, in addition to higher transparency on charges and efficiency from consultants. It additionally echoed requires advisers to be introduced throughout the scope of FCA regulation.
However regulatory issues that consultants pushed complicated merchandise on trustees — a lot of whom aren’t monetary consultants — and the problem of assessing the standard of the recommendation trustees obtain stay unresolved.
Dealing with of conflicts of curiosity for advisor companies that home advisory practices alongside fiduciary administration arms — the place funding selections are delegated by the trustees to the enterprise — can also be a key concern for the regulator.
“There are undoubtedly some fairly main conflicts within the trade, which nonetheless want addressing . . . by way of being each the assessor of asset managers and the supervisor of belongings themselves by means of their implementing orders,” Peter Harrison, chief govt of Schroders, informed a Monetary Occasions summit final month.

Some view makes an attempt to forged the highlight on consultants as blame-shifting, nevertheless, as prime LDI managers together with BlackRock, Perception Funding, Authorized & Common, Schroders and Columbia Threadneedle look to defend their reputations.
“Peter’s statements on regulation of consultants run the chance of it wanting like . . . he’s attempting to deflect the story on to another person,” stated one pensions advisor, stating that corporations corresponding to Schroders and BlackRock even have in-house advisory companies in addition to fiduciary administration operations.
“There are in fact conflicts on this enterprise, I’m not trying to minimise that, however [these firms] even have all of them in spades . . . He’s throwing stones in a really fragile glass home,” the individual stated.
Sir Nigel Wilson, chief govt of prime LDI supervisor Authorized & Common, claimed the insurer was the “employed assist” in such constructions, and confused the function of the consultants in guiding schemes’ selections. “We don’t advise them to advise their shoppers,” he informed friends, saying that just about all communication with the schemes went by means of advisers corresponding to Aon and Willis Towers Watson.
Mercer and Aon had each warned shoppers over the summer season about dangers to their LDI hedges as UK bond markets offered off.
Within the aftermath of the disaster, “trustees have had ‘stewards inquiries’ happening and the exhausting questions are being requested”, stated James Brundrett, a companion at Mercer. “There’s a debate about pooled versus segregated LDI funds but additionally, did we now have the very best LDI supervisor?”
One other advisor to pension funds stated that in the course of the disaster some LDI managers have been “not speaking” with advisers over how their pension shoppers have been positioned. “They wouldn’t inform us what was occurring [but] they have been telling us they wished collateral,” the individual stated. LDI is a “complicated enterprise and [the consultants] are a very substantial a part of that equipment”, they added.
After regulatory intervention averted a deeper liquidity disaster, many pension funds are anticipated to have emerged from the disaster with stronger funding ranges now their liabilities have been shrunk by increased gilt yields.
However the trade continues to be poring over whether or not UK schemes took on an excessive amount of danger in an try to shut their funding gaps, whether or not stress testing and collateral ranges have been adequate, and whether or not the recommendation to schemes on these points was enough.
“I don’t suppose anybody made big cash promoting LDI by means of consultants — it’s not high-margin and it’s fairly scaleable,” the UK institutional supervisor stated, however “it’s a bit bizarre that consultants aren’t regulated [when] the little one-man-band monetary adviser on the excessive road is”.
One other insurance coverage govt, talking on situation of anonymity, stated consultants have been “in a little bit of a panic” because the blame recreation heated up. “If you’re a fairly large scheme . . . I believe you’ll go after your adviser.”
Willis Towers Watson and Aon declined to remark.
Extra reporting by Josephine Cumbo