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 had 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 crisis 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 said. “And the product they’ve been pushing for the previous couple of years has been leveraged LDI.”
Liability-driven investment requires pension funds to focus not on asset development 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 akin 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 a whole bunch of billions in property to satisfy 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 property globally, in response to the UK’s Monetary Conduct Authority. Within the UK, the pension guide trade is each vastly influential and notably concentrated, but its funding recommendation to trustees will not 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 primarily based on proportion of consumer property, in response to 2017 estimates from the FCA that trade specialists don’t consider have shifted a lot since. For outlined profit pension schemes, the a part of the market that obtained into hassle, the proportion might be larger.
“The funding guide is fairly elementary to DB pension funds within the UK,” stated one supervisor who works with pension purchasers 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 because the LDI disaster after a earlier try and convey it beneath the FCA’s remit faltered through the pandemic regardless of gaining broad assist from traders, trustees and the key consultancies.
“Maybe if [pension fund] advisers had been extra delicate to coping with ranges of stress like this, a few of that threat would have been managed extra successfully,” FCA boss Nikhil Rathi informed a parliamentary committee in November.
Nonetheless, he added that “I wouldn’t go as far as saying that, in and of itself, would have prevented such a scenario.”
Focus within the recommendation market is a key concern for regulators, though opponents to the large three — together with Lane, Clark & Peacock and Redington — have gained market share lately. The rise {of professional} trustees at UK pension schemes can also be thought to offer some ballast to the dominance of guide 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 impartial analyst.
However Nangle doubts whether or not extra complicated merchandise had been favoured by consultants for their very own sake. “Schemes have used leverage to resolve 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 essentially because of particularities of the regulatory regime, which calls for a deal with schemes’ funding ranges, and accountancy requirements launched within the Nineteen Nineties that pressured 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 answer. By 2022, UK outlined profit pension scheme liabilities had grown to about £1.8tn, in response to LCP, 85 per cent of which was hedged utilizing LDI.
The Competitions and Markets Authority introduced numerous new measures in 2018 to allay trade issues over governance, requiring trustees to run tendering processes on fiduciary administration preparations, in addition to better 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 specialists — and the issue of assessing the standard of the recommendation trustees obtain stay unresolved.
Dealing with of conflicts of curiosity for guide 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 positively 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 property themselves via their implementing orders,” Peter Harrison, chief government 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 high LDI managers together with BlackRock, Perception Funding, Authorized & Normal, Schroders and Columbia Threadneedle look to defend their reputations.
“Peter’s statements on regulation of consultants run the danger of it trying like . . . he’s making an attempt to deflect the story on to another person,” stated one pensions guide, declaring that corporations akin to Schroders and BlackRock even have in-house advisory companies in addition to fiduciary administration operations.
“There are after all 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 particular person stated.
Sir Nigel Wilson, chief government of high LDI supervisor Authorized & Normal, claimed the insurer was the “employed assist” in such buildings, and pressured the position of the consultants in guiding schemes’ selections. “We don’t advise them to advise their purchasers,” he informed friends, saying that almost all communication with the schemes went via advisers akin to Aon and Willis Towers Watson.
Mercer and Aon had each warned purchasers over the summer season about dangers to their LDI hedges as UK bond markets bought off.
Within the aftermath of the disaster, “trustees have had ‘stewards inquiries’ happening and the onerous 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’ve got one of the best LDI supervisor?”
One other guide to pension funds stated that through the disaster some LDI managers had been “not speaking” with advisers over how their pension purchasers had been positioned. “They wouldn’t inform us what was taking place [but] they had been telling us they wished collateral,” the particular person 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 larger gilt yields.
However the trade continues to be poring over whether or not UK schemes took on an excessive amount of threat in an try to shut their funding gaps, whether or not stress testing and collateral ranges had been enough, and whether or not the recommendation to schemes on these points was ample.
“I don’t suppose anybody made enormous cash promoting LDI via 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 government, talking on situation of anonymity, stated consultants had 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.
Further reporting by Josephine Cumbo