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CDC: “How do you make it fair?” not through liability driven investment!

The point of multi-employer CDC is that you share things. You cannot run a scheme on a lifestyle basis, where you invest for how long your members are going to choose to be in the scheme, you must assume they will be in it till they die. You cannot invest collectively for an individual or even one group of people within a wider group.

It is a difficult fact for our investment community to pick up  but the CDC investment strategy is not liability driven. The liability driven concept of investment , occurs only when there is a finite duration to the investment, but CDC is not finite, so long as there are new companies to replace old companies, new employees to replace those who are no more, there will be no end to a CDC plan. Please refer to Derek Benstead’s chart.

We had infinite time horizons for DB and now we have infinite time horizons for CDC, we must not invest for failure, that does not work.

I will give as an example a panel conversation held at Manchester which shows how a panel of experts still apply the principles of LDI – that the scheme’s duration is finite, to CDC – where it isn’t.

I thank Sandra for writing up this conversation, but it is not a very sensible conversation, I have put in red the comments of the participants that confuse CDC without finish with DC and DB schemes with closure ahead.

The only thing that the investment strategy of a CDC has to take into acc0unt is that it is paying a pension to everyone in the scheme eventually. Everyone that leaves – is replaced, the sweet-spot remains so long as confidence in pensions remains.


Sandra Wolf
CDC: How do you make it fair?
14 October 2025 

CDC: How do you make it fair?

Sophie Dapin, Krista D’Allesandro,  Iain McLellan and Tegs Harding

Guidance should be issued on which categories of scheme members can be pooled together in collective defined contribution schemes, one panellist said as questions of fairness were at the heart of a debate on CDC at the Annual Conference 2025 by Pensions UK.

CDC offers the promise of better outcomes, if not necessarily fairer ones. But while cross-subsidies based on age will not be allowed in multi-employer CDC, there are questions on how other characteristics that feed into life expectancy lead to cross-subsidies.

How CDC schemes are designed is key for input and outcomes, including what people perceive to be fair. In CDC, intergenerational fairness has been a key concern, but there are different ways of looking at this, panellists at the conference suggested – and the mechanistic nature of CDC means design is key.

“That design is really, really important, and it comes down to how are you actually defining what you get out for what you pay in, and who you put in the same pool. And that last bit, there’s no obvious right answer to”

said Tegs Harding, a professional trustee at Independent Governance Group who sits on the Royal Mail Collective Pension Plan.

“I’m hoping that we’re going to get some more guidance down the line.”

The UK has a very pronounced life expectancy inequality problem, Harding said.

“If you are a male lorry driver living in Blackpool, you can expect to live around 10 years less than a female lawyer living in London. And the problem is, if you put those two people in the same pool, you can predict in advance who is paying whose pension at the time. And there’s a question of fairness around that”   

Different issues intersect in that example, she noted – profession, income, gender and location.

In theory, if you were thinking about actuarial equivalence or making it actuarially fair, you might want to put all four of those different groups in different pots” .

The rules for multi-employer CDC, set to come in later this year, are clear about not permitting designs where younger members subsidise older members, noted Iain McLellan, a director at consultancy Isio.

The rules basically have a very strict requirement on age, but they don’t say anything about these other factors that Tegs has highlighted, gender, occupation, salary,

he pointed out.

The consultation on multi-employer CDC last year stated that

actuarial equivalence at an individual member level or at an employer level is essential for unconnected multiple employer CDC schemes to avoid cross subsidies between employers (which, for example, would occur if one employer has a younger workforce than another)”.

Although each group with different characteristics could be put into a separate scheme,

every time you take a cut you make your pool smaller”,

McLellan cautioned.

You may avoid some problems, subsidies, but you end up [with] cliff edges between these kinds of gaps.

The reality of “sharing” is that people do it. They do it in the state pension and they do it it in DB plans. Rich people who want to have their wealth managed for them , opt-out and this is good for the pool as they tend to be the long livers.

Male lorry drivers can be invested in a pool with female investment managers but we cannot set up liability driven investments for both separately. We set up one investment strategy for everyone with the longevity of the pension scheme liabilities being infinite.

Ultimately, older schemes will be invested in by young people, because sharing works like that, when you get big CDC schemes with people joining (when they start working) and leaving (when they die) with companies joining and leaving for the same reasons, then you can say things balance themselves out over time.

Trying to engineer schemes to meet your investment strategy is crazy, instead we should be setting up an investment that suits the sweet spot and does not invest for failure. LDI is admitting failure, so is lifestyling. The liabilities of a CDC fund need to be matched by the pay-outs , there is good stuff in the consultation about cohorts and there’s a lot of thinking about chain-linking which actuaries can discuss.

Can you imagine turning away employers from a multi-employer pension scheme because you thought they had staff who lived too long? Can you see good in planning a CDC investment strategy that didn’t cater for new employers as well as employers leaving. Can you plan for nobody new joining as well as older people dying? That’s the thinking of DB being  closed to new joiners – it leads to no future accrual and closure.

All the good thinking  is about pay-outs. The investment stuff is incredibly simple and does not to be liability driven, unless the scheme has failed or is planning to.

 

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