New Pension Accounting Standard: A Game Changer!

1. Wednesday, October 16, 2013 Citrus Hills Golf and Country Club Hernando, Florida New Pension Accounting Standard:A Game Changer! NATURE COAST CHAPTER GOVERNMENT FINANCE OFFICERS ASSOCIATION (LOCAL CHAPTER OF THE FGFOA) Bert A. Martinez, CPA Purvis, Gray and Company, LLC Senior Audit Manager Sarasota Office BAM@purvisgray.com

2. Introduction • Two new GASB Statements have been issued in June of 2012; • GASB No. 67 – Financial Reporting for Pension Plans, an amendment of GASB No. 25 • Effective for Plans in FYE 2014 • GASB No. 68 – Accounting and Financial Reporting for Pensions, an amendment of GASB No. 27 • Effective for Employers in FYE 2015

3. Introduction • The GASB’s long and deliberative process • Added to research agenda in January 2006 • Added to project agenda in April 2008 • Invitation to Comment issued in March 2009 • Preliminary Views issued in June 2010 • Exposure Drafts issued June 2011 • Since then, the GASB has reaffirmed most of the ED • Final Standards adopted and issued June 2012

4. The Presentation in 1 Slide • The Big Picture • Local Governments will now be required to record the liability for their unfunded defined benefit pension plan obligations to their employees within their economic resource based financial statements, rather than merely disclosing this amount in the notes to the financial statements as was previously required under GASB No. 27. • The formula for calculating the liability is similar to the old UAAL found in notes to FS under GASB 27, with some differences in how the components are calculated.

5. Scope • Provisions apply to employers with employees covered under: • defined benefit pension plans and • defined contribution account balance plans • Provisions apply to employers with employees covered under: • Single employer plans (e.g., local plans) • Agent multiple employer plans • Cost sharing multiple employer plans (e.g., FRS)

6. Scope (continued) • Provisions apply to financial statements that use the economic resources measurement focus • Government-wide/proprietary fund financial statements • Not governmental funds statements • Provisions apply to all employers subject to GASB standards for issuing GAAP financials: • States and school districts • Cities and counties • Other governments and districts

7. Implementation • New Standard’s Provisions are Retroactive • Balance sheet liability - restate with a beginning balance • Deferred inflow/outflows accounts - restate with beginning balances if information to do so is available, else start with zeroes • Unlike OPEB’s transition treatment ( which may soon change)

8. Significant Provisions • “Worse” Provisions: • Heavy use of deferred inflow and deferred outflow accounts (GASB No. 63) • Immediate recognition in pension expense of all plan changes; some say this is good • Much more disclosure; some say a little more would be good • More costly to comply • Pension expense method will cause more confusion than clarity

9. Significant Provisions • “Worser” Provisions: • The new rules for cost sharing employers (e.g., Florida counties and school districts in FRS) will be just like the new rules for employers with local plans • Throw away everything you ever knew about govt. pension accounting • Lots more work with communications challenges • Large new liability on the balance sheet • Unstable/volatile income statements and balance sheets

10. Significant Provisions • It could have been even “worster” (since the ED): • The GASB delayed the effective date for the employer financial statements - FYE 2015 • But still FYE 2014 for standalone Plan financials • Since the ED, the GASB made several cost-reducing changes: • Combined actuarial gains/loss for actives and inactives • Measurement date anytime between reporting date and prior fiscal year end; gives more time to prepare entries and disclosures

11. The GASB Files for Divorce ! • Government-wide employer accounting and funding have been delinked, decoupled, . . . DIVORCED !

12. The Marriage • Government-wide employer accounting and actuarial funding/contributions have been ONE • Old GASB Statement No. 27 (current) • The employer’s obligation is to fund the plan • The accounting expense (APC) -- an actuarial funding contribution • The balance sheet liability -- contribution shortfall Member Employer Plan Funding Obligation

13. The Marriage • Government-wide pension accounting expense was based on the Annual Required Contribution (the “ARC”) for sole and agent employers • The ARC was: • usually a reasonable number for funding purposes, • determined under fairly stable methods, • a benchmark – users knew if a government was funding its pension obligation adequately, and • known in time for budgeting a funding contribution

14. The Divorce • Accounting and actuarial funding will be separate • The GASB has found a new, completely new, way to define the government-wide expense and liability • “We do accounting; actuaries do funding.” – Bob Attmore, GASB Chairman

15. The Marriage • Remember how the GASB looked at it this way: • Old GASB Statement No. 27 (current) • The employer’s obligation is to fund the plan • The accounting expense (APC) -- an actuarial funding contribution • The balance sheet liability -- contribution shortfall Member Employer Plan Funding Obligation

16. The Divorce • Now the GASB is looking at it this way: • New GASB Statement No. 68 • The employer’s obligation is “ultimately to the members” • The accounting expense -- not determined w.r.t. to anyactuarial funding contribution Member • The balance sheet liability --an unfunded actuarial accruedliability Benefit Obligation Employer Plan

17. The Divorce • Accounting expense will not be viable for funding • Too volatile for contributing • No more ARC, APC or NPO • Two sets of numbers – • One set for accounting and financial reporting purposes • One set for actual funding/contribution purposes

18. Net Pension Liability (NPL) • The Net Pension Liability is the new, different and much larger balance sheet liability - the entire Unfunded Actuarial Accrued Liability • NPL = Total Pension Liability (TPL)minus Fair Value of Plan Assets (FVA) (aka Plan Net Position) • TPL is calculated using only one actuarial cost method, to achieve better comparability

19. Total Pension Liability (TPL) • TPL = Actuarial Accrued Liability (AAL) determined under the traditional Entry Age normal (EA) actuarial cost method • Not the so-called Ultimate EA • Not the Frozen Entry Age or Frozen Initial • Not the Projected Unit Credit method

20. Total Pension Liability (TPL) • The interest discount rate used to calculate the TPL is determined by a specific and complex process • No details in this presentation because: • “Most” Florida plans will likely use only the long-term expected rate of return (LTeROR) for the interest discount rate • Disclosure will require that you describe how you determined your LTeROR

21. Net Pension Liability (NPL) • To summarize so far, the balance sheet liability is the Net Pension Liability (NPL) • NPL = Total Pension Liability (TPL) minus Fair Value of Plan Assets (FVA) (aka Plan Net Position)

22. Statement of Activities • Expense is “based on” the change in the NPL from one year to the next • There are many reasons for the NPL changing from one year to the next • There are many different components of the total change in NPL from one year to the next; and different components are treated differently

23. Statement of Activities • NPL = TPL minus FVA • The total change in NPL is separated into: • Changes in the TPL from one year to the next and • Changes in the FVA from one year to the next

24. Statement of Activities • These components of each year’s change in the TPL and FVA are either: • Immediately recognized in the expense in full, OR • Gradually recognized in the expense and deferred • Some components are amortized/recognized over the average expected service life of plan members • One component is recognized over a fixed five year period. • Gradually recognized components of change may be amortized for expense recognition using straight-line, level-percent-of-pay, etc.

25. Statement of Activities • Immediate recognition of TPL changes: • Service cost (normal cost) attributed to the year • Interest (at the discount rate) on last year’s TPL • Actual benefits paid for the year • All plan benefit changes • Other changes in the TPL from one year to the next • Gradual recognition TPL change: • Assumption changes • Actuarial gains/losses (liability side)

26. Statement of Activities • Immediate recognition of FVA changes: • Projected investment earnings • Actual benefits paid for the year • Administrative expenses paid for the year • Actual contributions made for the year by employer(s), by employees, by retirees and by other sources without a “legal obligation” to contribute • Other changes in the FVA from one year to the next • Gradual recognition FVA change: • Difference between projected investment earnings and actual investment earnings for the year

27. Nine High-Level Implications • A new and very large balance sheet liability • Pension expense (or pension income) • Unstable financial statements • Spot light on pension liabilities • Communication challenges • Re-visit funding policies • Additional disclosures • A lot of work • Get it right

28. Nine High-Level Implications • Net Pension Liability (NPL):a new and very large balance sheet liability • Pension expense - or pension income

29. Nine High-Level Implications • Unstable employer financial statements . . . • due to the use of the fair value of plan assets, instead of a smoothed actuarial value, as the offset to the TPL in the balance sheet liability (NPL) • due to immediate recognition of benefit changes • due to short amortization/recognition of other sources of change in the TPL • due to short amortization/recognition of investment return deviations from expected

30. Nine High-Level Implications • Spot light on pension liabilities . . . • Moves the liability from the Notesto the Balance Sheet • Pension liability will have a higher profile in the CAFR • Could make the government’s Net Assets (now being called Net Position) to be negative when it would otherwise have been positive • Could add more fuel to pension roll-back movement

31. Nine High-Level Implications • Communication challenges . . . • With the press, legislators, local elected officials, plan trustees, participating employers, your city manager - executive director - superintendent, etc. • “So which is the true unfunded liability?” • “So which is the true expense?” • Delete ARC, APC and NPO from our vocabulary • Forget everything you knew about government pension accounting

32. Nine High-Level Implications • Re-visit funding policies • Cannot just lean on an ARC to set funding level • City and Board jointly adopt a Funding Policy • Actuarial cost method • Robust, disciplined, unbiased and well-documented process for setting the long-term expected rate of return • Amortization periods and methods • Target dates for funded ratios • Other related matters such as risk management, volatility management, etc.

33. Nine High-Level Implications • Additional disclosures – Typically: • In the Notes to Financials • Changes in NPL • Significant Assumptions – discount rate, mortality, etc. • Numerous other disclosures • In the Required Supplementary Information • 10 Year table(s) for: TPL, Plan Net Position, NPL, Net Position as a % of TPL, Covered Payroll (PR), NPL as % of Covered Payroll, Required & Actual Contributions, Covered PR, Contributions as % of PR. • Other disclosures

34. Nine High-Level Implications • A lot more work • For the implementation year and • For subsequent years • More actuarial work • More preparer work • More auditor work • More work More costs

35. Nine High-Level Implications • A lot more work (continued) • One actuarial report for funding purposes • Methods are driven by Funding/Contribution Policy • Timing is driven by budget timetable • One actuarial report (or two) for accounting purposes • Methods are driven by the GASB standard • Timing is driven by the GASB Standard and CAFR timetable

36. Nine High-Level Implications • A lot more work (continued) • Much more disclosure language and tables for preparer • This presentation did NOT cover very much of the substantial amount of disclosures in the Notes and RSI for the employer’s FS or for the plan’s FS • More work and attention by auditors

37. Nine High-Level Implications • Get it right • The GFOA is watching (Certificate of Achievement) • Taxpayers and their watchdog groups are watching • The press is watching • The SEC is watching

38. Employer Liability (Asset) • Assume for example, that an employer previously contributed the full amount of it ARC each year. Also assume the following facts for the current year: • Actuarially determined employer contribution = $100; • Actual employer contribution = $90; • Total employer pension liability (end of period) = $10,000; and • Plan net position (end of period) = $9,300 • Currently, the employer would report a $10 liability (NPO) as a result of its failure to fully fund its actuarially determined contribution for the current year:

39. Employer Liability (Asset) cont. Actuarially determined employer contribution $100 Less: Actual employer contribution 90 NPO (liability) $ 10 In the future, the employer would instead report a $700 liability that represented the amount by which its total pension liability exceeded plan net position: Total employer pension liability $10,000 Less: Plan net position 9,300 Employer net pension liability $ 700

40. Discount Rate

41. Actuarial Method

42. Pension Expense

43. Deferral and Amortization

44. Changes in Economic and Demographic Assumptions

45. Differences between Economic and Demographic Assumptions and Actual Experience

46. Difference between the Expected Rate of Return on Plan Investments and Actual Experience

47. Cost-sharing defined benefit plans Assume, for example, the following facts regarding a cost-sharing pension plan and one of its participating employers (City of Example): Total pension liability—all participating employers $10,000 Total plan net position $8,500 Contractually required contributions for current period City of Example: $5 Employers—total: $100 Actual contributions for current period City of Example: $5 Employers—total: $100 Further assume that the contributions of participating employers are expected to remain stable over the long term in relation to employer contributions in total.

48. Cost-sharing defined benefit plans (cont.) Currently, the City of Example would not report any liability since it paid its contractually required contribution in full. In the future, however, the City of Example will have to report its proportionate share of the total net pension liability, calculated as follows: Total pension liability—all participating employers $10,000 Less: Total plan net position 8,500 Net pension liability—all participating employers $ 1,500 City of Example’s proportionate share of total contribution effort: $5 City of Example/$100 employers in total = 5% City of Example’s proportionate share of total net pension liability: $1500 Net pension liability—all participating employers x .05 City of Example’s proportionate share of contribution effort $ 75 Net pension liability—City of Example

49. GASB Implementation Guide to Statement No. 67 • Intended to serve as a reference guide and an instructional tool to help • readers in applying provisions of Statement No. 67 • Released in June 2013, one year after Statement No. 67 was approved • Questions and Answers (pages 1 to 27) – these ninety-nine Q&A’s are • serve two purposes: • 1) Ready references for implementers who may encounter similar • questions or situations. • 2) Provide a basis for resolving issues that an implementer may apply to • a question or situation not specifically addressed in this Guide. • Glossary of terms (forty) are presented in Appendix 1 (pages 29 to 33) as • they are used in Statement 67. The terms may have different meanings in • other contexts. • Appendix 2 (pages 35 to 48) – Summary of the Standards of Governmental • Accounting and Financial Reporting of this Statement for state and local • government pension plans. Includes a summary of the notes to financial • statements and required supplementary information.

50. GASB Implementation Guide to Statement No. 67 • Appendix 3 (pages 49 to 92) – presents expanded illustrations from Statement 67, along with two additional illustrations developed for this Guide. • 1) Calculation of Money-Weighted Rate of Return – required by para- • graph 30b(4) of No. 67. Considers the changing amounts actually • invested during a period and weights the amount of pension plan • investments by the proportion of time they are available to earn a • return during that period. • 2) Reconciliation of Amounts Presented in the Financial Statements • to Amounts Used in Determining Money-Weighted Rate of • Return – key components include beginning and ending investments, • and net external cash flows into and out of pension plan investments. • 3) Calculation of the Discount Rate – example of the projections and • calculations used to determine the discount rate as required by para- • graphs 40 to 45 of Statement No. 67. • a) Table 1 – Projection of Contributions – assumed to be projected • cash flows into and out of pension plan.