The National Pension Commission (“PenCom”) recently published/released the Amended Regulation on Investment of Pension Fund Assets for the Pension Industry. The new investment guideline introduces a multi-fund structure, which would replace the “one size fits all” structure that puts all active contributors into one Retirement Savings Account (“RSA”) Fund without consideration for age or risk profile of such contributors.
What is the multi-fund structure?
The Multi-Fund structure is a framework that aims to align the age and risk profile of RSA holders by dividing the RSA Fund into four distinct Funds. The current RSA Fund will be sub-divided into three separate Funds, while the RSA Retirees Fund would be the 4th Fund.
What is the difference between the 4 Funds?
The respective funds differ based on their overall exposure to variable income instruments such as equities (that is, Ordinary Shares) and the age profile of the members.
Exposure to Variable Investment Instruments
|Fund I||20% to 75% of Portfolio||Only on request but not accessible to Retirees and active contributors of 50 years and above.|
|Fund II||10% to 55% of Portfolio||Default fund for RSA holders of 49 years and below|
|Fund III||5% to 20% of Portfolio||Default fund for RSA holders of 50 years and above|
|Fund IV||0% to 10% of Portfolio||Only for Retirees|
Q. What are variable income instruments?
Variable income instruments are investments that generate income or returns that cannot be pre-determined from the date the investments were made. In addition, the prices of such instruments fluctuate daily. Instruments in this category include Ordinary Shares, Collective Investment Schemes (“CIS”) such as Mutual Funds, Real Estate Investment Trust; Infrastructure Funds and Private Equity Funds.
Such investments have potentials to generate high returns over the long term but could be risky owing to uncertainty and fluctuations in market prices and returns.
Q. What has age and risk profile got to do with how my pension funds are invested?
In investing money, everyone has a limit to the amount of risk that they can take and the amount of uncertainty they can handle. This is known as risk tolerance. Typically, younger people tend to have more capacity for risk because they still have time to recover from loses (if any). Once a person is nearing retirement, it is advisable that they limit the amount of risks they take and reduce exposure to uncertainty as they would start drawing down on their pensions within a short period.
Consequently, the allowable exposures to variable income instruments have been designed such that Fund I has the highest allowable limit, followed by Fund II, III and IV respectively. This reduces the risk and uncertainty of contributors in line with their ages.
Q. Can I decide which Fund Type to be assigned to?
On the day of commencement, a default mechanism shall apply. According to the default mechanism, all active contributors that are 49 years and below would be placed in Fund II while active contributors that are 50 years and above would be placed in Fund III. Subsequently, an active contributor can make a request to his PFA to move between Funds subject to certain restrictions. An active contributor of 49 years and below can opt for Fund I, while an active contributor in Fund III may elect to be assigned to Fund II. However an active contributor in Fund III is not allowed to opt for Fund I while an active contributor in Fund II is not allowed to opt for Fund III. Fund III is strictly for active contributors above 50 years. To be assigned to any fund based on the preceding, an RSA holder must make a formal request to his/her PFA.
Q. How often can I move between Fund types?
An active contributor may switch from one Fund type to another Fund type within a PFA, once in 12 months without paying any fees (subject to a formal application).
Any additional requests for switches among Funds within a 12 month period by the active Contributor shall attract a fee, of an amount not less than a minimum value, to be determined by PenCom from time to time.
Q. When will the 12 month period start counting, will it be from the date of commencement or from the date of my first switch?
PenCom will provide details on the 12 months period in the operational framework that would guide the transition to the Multi-Fund structure.
Q. Are there any benefits in this multi-fund structure?
Of course there are. The new structure allows RSA holders more control over how their pension funds are invested based on their risk tolerance. For instance, an RSA holder in Fund III owing to the default classification based on age, may have more tolerance for risks and uncertainty and could opt to be assigned to Fund II.
Q. Can I choose a Fund type right now?
Yes. The implementation of the new Fund structure commences from July 1st, 2018. Contributors are to go to their Pension offices and request to choose their preferred Fund, subject to the guideline requirement, and after you must have been put through by your PFA.
Q. Who takes the ultimate switch responsibility between the contributor and the PFA?
Whilst the contributor has the right to switch between funds depending on his or her preference, the PFA will be responsible for effecting the switch upon receipt of a formal request from the contributor. The PFA is also in a position to provide financial advice to contributors to assist in assessing risk and making an informed decision.
Q. What are the impacts on my pension balance when my PFA moves into the multi-fund structure?
The balance in your RSA will not change due to the movement to the multi-fund structure because the entire balance would be moved to the appropriate fund without charges. However subsequent growths in your balance would depend on contributions such as the mandatory monthly contributions, voluntary contributions as well as returns generated by the PFA on that particular fund.
Q. What is/are the requirement(s) for switching from one fund type to another?
In order to switch from one fund type to another, a formal request must be submitted by the contributor to his or her PFA.
Q. Do I need to seek an advice from external financial advisor or my PFA before taking a decision to switch?
Whilst you are at liberty to seek advice from external financial advisers, we would make information available on the fund performance and indices to enable you take an informed decision.
Q. If my date of birth is wrongly captured, which Fund Type will my PFA profile me?
You still have the opportunity to check and update your records with your PFA before the commencement of the transition.
Q. Will I be able to move back to the preferred fund free of charge after my date of birth correction (especially when my date of birth was wrongly captured by my PFA)?
Yes, you will be able to move free of charge given that a contributor has the option to move for free once within 12 months. However, you still have the opportunity to check and update your records with your PFA before the commencement of the transition.
Q. Can I split my voluntary contribution in a separate Fund Type while my mandatory goes into another Fund Type?
Every RSA holder is entitled to only one Pin for all types of contributions. Consequently, your voluntary contribution will be in the same Fund as your mandatory contribution.
Q. Will the RSA and VC funds have separate fund price or the same?
The RSA and VC will have the same fund price because they will be invested in the same fund the contributor selects.
Q. How will the Fund Prices under the Multi-Fund Structure be determined at the point of crossing over to the new structure and what would happen to the Old Fund Price and units?
PenCom would provide guidance to how the fund price and units would be treated in the operating framework that would guide the transition.
Q. What impacts does Multi-Fund structure have on my future pension assets at the point of retirement?
The Multi-Fund structure provides more alignment between your retirement goals, risk appetite and age. Consequently, there will be a better chance for your pension assets to meet your expectations when you retire.
Q. Once an RSA holder makes a withdrawal such as 25% and then becomes unemployed, can he request that his funds be moved to another fund structure since no contributions are entering his RSA?
The regulation does not restrict movements due to withdrawal of 25%. As long as the individual is below 50 years, the option is to switch between Fund I and Fund II.
Q. Is it possible for a client below 50 years to move to fund III?
No, Fund III is strictly for active contributors of 50 years and above.
Q. If I decide to switch from Fund II to Fund I, can I switch back to Fund II?
Yes, but it will be at a cost if you intend to switch back to Fund I within 12 months.
Q. Will I have access to the financial reports of other funds?
The annual financial reports of the RSA Funds of all PFAs are published once a year in at least 2 national dailies. In addition, the fund prices would be published daily on the websites of the PFAs.
Q. With the new multi-fund structure, can I be given the option to choose which specific variable income instruments my funds can be invested in?
No, the regulation only allows contributors to select a Fund, but the PFAs would continue to have the responsibility of selecting the specific instruments that the Funds would be invested in.
Q. Will the charge for moving between funds be deducted from the RSA or paid as a separate amount in to the bank?
The charge would be deducted from the RSA balance of the contributors
The new PFA will be responsible for managing pension assets of the entire Nigeria Police Force personnel according to the Pension Reform Act (PRA 2014).