Tuesday, 13 January 2015

Diversification without Diversification: Can the Multi-Pillar Pension Structure in Ghana Engender Diversification Risk in Pension Fund Management ? (Part I)

The road to pension liberalization was largely necessitated by unsustainable pension systems in Ghana. While the social insurance of family ties is weakening in recent times, the formal pension system prior to 2008 was like HIV/AIDS as described in some academic publications; meaning it was a slow-but-sure killer. The history of pensions in Ghana is marked by inadequate pension income, corruption and mismanagement. During this period, the pension system had just one pillar, which was a define benefit (DB) scheme. A DB scheme is a promise by a sponsor (in this case government) bearing responsibility to pay a fixed life annuity; sometimes inflation-adjusted and benefits are a function of both years of service and wage history.  Since DB schemes enables the pooling and group management of funds, it provides risk-sharing properties that are not captured by Defined Contribution (individual pension accounts) models. However, they were unfunded, in that funds were not set aside for the payment of pensions; rather, pensions were paid from tax revenue whenever due; thus, earning the name pay-as-you-go pension.

The growing number of pensioners and slow economic growth increased the cost of pensions to the government and practically made it unsustainable to maintain an unfunded one pillar DB pension system. It is within this pension sustainability debate that the almighty concept of liberalism, which has gain grounds since the 1980s due to what was referred to as the “the crisis of the welfare state” in the west and the “weakness of post-colonialist bureaucracies” infected global pension schemes. In simple terms, pension liberalism implies the privatization of pensions and retirement planning mainly through Defined contribution (DC) schemes. In this wake and championed by the World Bank in a report entitled “Averting the old Age Crisis”, a three-pillar pension scheme including a mixture of DB and DC schemes were proposed to salvage the looming global pension crisis.  Although the World Bank didn’t make a direct contribution as argued by Kpessa (2011), its ideology was lingering in the mind of the Bediako Committee that undertook the pension reform in Ghana. Hence, the reason for the current three-pillar pension system in Ghana.

In this article, which is Part I of these series, I wish to share with readers some insights into the inherent risk of the neoliberal new three-pillar pension system in Ghana, which we shall refer to as “diversification risk”. This risk potentially exist as a result of the separation of the management of first and second mandatory pension contributions. While the separation of the management function provides diversification benefits, it also engenders risk given the high level of financial illiteracy in Ghana. Therefore, to borrow the words of the English Poet John Keat (1819), the separation process embodies the “Contrarieties of Life: the Irreconcilable but Inseparable Opposites of Life” – where there is life, there is death. In this case, its advantages could be in itself a disadvantage from a portfolio management perspective. This implies that merely dividing the pension system into three tiers does not necessarily mean diversification although one of the goals of the new multi-pillar pension system in Ghana (Kpessa, 2013; 2011; World Bank, 1994). I will work through some simple estimations to demonstrate the phenomenon of diversification risk. The rest of the article will focus on describing the latent diversification risk in our new pension system and how it could manifest and be magnified by financial illiteracy and information asymmetry – unequal information among economic agents; i.e. pension fund managers and pension contributors who make investment decisions.

The Bediako Commission set up in 2004 led to the enactment of the current National Pension Act, 2004 (Act 766) to introduce a contributory three-tier pension scheme to provide improved retirement benefits for all workers. The ACT requires employers to contribute 13% and workers 5.5% of gross income, making a total contribution of 18.5%. This distribution is presented below:

a.     First tier basic national social security (defined benefit –DB) (13% out of total contributions); which is managed by the Social Security and National Investment Trust (SSNIT) is mandatory for all employees in both the private and public sectors. 2.5% out of 13% is a levy for the National Health Insurance scheme;

b.     Second tier mandatory occupational (or work-based) “defined contribution (DC)” pension scheme (5% out of total contribution) is “fully funded” by employees and privately-managed by approved Trustees assisted by Pension Fund Managers and Custodians. It is designed primarily to give contributors lump sum benefits.

c.     Third tier voluntary provident fund and personal pension schemes, supported by tax benefit incentives for workers in the informal (blue collar) and formal sectors (white collar).


The three tiers (pillars) of the new pension system constitute a portfolio of pension investments, which has investment diversification as one of its goals. Under section 176 – Permitted Investments, pension fund managers have nine classes of investments to choose from, which broadly cover a host of capital market and money market investments. These include shares (ordinary and preferential), bonds (government and corporate), Treasury bills, investment funds like mutual funds and unit trusts, debt securities and real estate, etc. Each of these investments have unique risk and return profiles (behaviours) and are likely to provide diversification benefits as investment portfolio management requires. The principle of diversification implies putting your eggs in different baskets, so that in the event of loss, some baskets of eggs (investments) may be saved. In other words, as one basket of investments is doing well, another may be doing badly, so that the performance of the latter is compensated for by the former. Therefore the average (mean) return is the expectation of the investor. Where all investments are put in one basket, the mean is the same as the total return on the one basket of investment, which may increase the risk of the investment portfolio  without commensurate return.

Diversification Risk and the Separation of the Pension Management Function
Diversification is thus effective when selected investments behave differently. In the one basket investment scenario above, all the investments behave the same and likely to provide little or no diversification potential. However, in the different investment basket scenario, diversification is likely to be maximized; i.e. returned maximized and risk reduced. Diversification is most effective when the pension fund manager has perfect information about the investment types he/she is investing in. In that case, he/she may not put all his eggs in one basket. A statistical measure of diversification is the correlation of returns, which measures the relationship between investment assets returns. The lower the correlation, the better the diversification potential; so zero and negative correlations may provide better diversification than positive correlations between assets. A zero correlation means that there is no relationship between the return behaviour of the portfolio of investments. A negative correlation means a negative relationship, so that when the returns on one asset (A) is moving up, the return  on asset (B) is falling and vice versa, which is preferred.  A position correlation indicates that returns are moving in the same direction, which is mostly not preferred. diversification therefore minimizes the volatility (risk) of asset returns whiles maximizing returns.

Although the new pension system is restructured and obviously divided (diversified) into three different baskets of investments, the benefits of diversification may be elusive as the separation of the management function comes with “information asymmetry” among pension fund managers. In this vein, the first tier DB social security scheme is managed by the SSNIT; the second tier DC will be managed by pension fund managers appointed by pension trustees on behalf of pension contributors; and the third tier by the NTHC as proposed. Since, the latter is voluntary, we will focus on the first and second mandatory schemes from here.

Private pension fund managers are experts in investing in particular financial instruments, say bonds or shares or real estate. Despite their expertise, the likelihood that they may lack information about SSNIT’s investments of the first tier DB funds cannot be compromise. Hence, the separation of the management function as a result of neoliberalism (privatization) potentially could create unequal information (asymmetry) between SSNIT and private pension fund managers of the second tier, which could have the effect of compromising the benefit of diversification as required by having different baskets of investments. In other words, although the structure of new pension system is diversified in theory, diversification in practice may be unachievable because the managers of the two different baskets of investments, SSNIT (first tier) and private pension fund managers (second tier) may invest in the same investments, say bonds or shares or real estate at the same time. In effect, they may end up putting all of contributors’ contributions in one investment basket. The failure of this one investment basket means that everything fails unlike a situation where investing in different assets may save some. For the purpose of understanding the concept of diversification risk, I will discuss two scenarios; (1) an undiversified portfolio and (2) a diversified portfolio.

For instance, if SSNIT and the private pension fund managers invested in the same real estate investment vehicle, which produced a return of zero (0%), then the SSNIT will receive zero (0%) and the private pension funds also zero (0%). The total and average returns are both zero (0%); [i.e. 0% + 0% = 0% and (0% + 0%/2) = 0/2 undefined]. This is the worst case scenario of an undiversified portfolio. However, if SSNIT invested in real estate and the private pension fund managers invested in bonds which yields zero (0%) and 5% respectively, then the average of the investments’ returns [i.e. (0% + 5%)/2 = 2.5%], which is 2.5% is what a contributor will earn. A contributor’s total return will be 5%, i.e. 0% + 5% in the diversification scenario. Thus, the low performance of real estate is offset by a positive high performance in bonds.  

Besides, the effect described above is not exactly as it will be, given that SSNIT’s investments are guaranteed by government; so irrespective of returns on their investment, government must provide a positive above zero return to contributors. Thus, government’s guarantee mitigates investment risk – the risk that the investment will fail. This is because pension pay-outs from the first tier DB scheme is not market determined but by a formula which incorporates the length of service and contribution rate (how much a contributor saved with the government). Hence, using the same undiversified scenario above, if real estate yields zero (0%), the private pension funds and for that matter contributors will receive 0% but the contributor will not receive 0% from government guaranteed SSNIT managed pension funds. This is because governments as mentioned above usually commit (guaranteed) to pay a minimum return to contributors on its borrowings from the SSNIT; say 2% above inflation.  In this case, the total return becomes 2%; [i.e. 0% + 2%] and the average return [i.e. (0% + 2%)/2] will be 1%, which is better than the first undiversified scenario without government guarantee above.

The picture is even better with diversified portfolios with government guarantee of 2% minimum return above inflation. To illustrate this with the first diversified scenario, if market returns of SSNITs investment in real estate is zero (0%) but the private pension fund managers earn 5% from investing in bonds, then the total return and average return will be 7% and 3.5% [ i.e. 2% + 5% = 7% and (2% + 5%/2%) = 3.5%] respectively. This example is particularly important because it demonstrates that the “unguaranteed” privately managed second tier pension scheme should be watched closely with both eyes since returns (real) could be practically zero and even negative because returns are determined by market forces, which are volatile and uncertain. The phenomenon of diversification without diversification (“diversification risk” trap) fuelled by information asymmetry may exist in all multi-pillar pension systems, even in the advanced economies.

In Part II of these series, I will look at how “financial illiteracy” among pension contributors and “their right to make investment choices in the second tier defined contribution scheme” could manifest and magnify the diversification risk potentially inherent in the new multi-pillar pension system in Ghana.  

Kenneth A. Donkor-Hyiaman
kwakuhyiaman@gmail.com





7 comments:

  1. The thrust of your piece if I understand you is that both SSNIT and the private managers virtually invest in the same market and in similar asset classes and that effectively limits any diversification benefits that were expected to accrue from the reform ... but SSNIT also invests in ventures that are not publicly traded which offers some diversification especially when most of the funds (13%) goes to them, something the private managers per the current pension law cannot do.

    My concern has been about the risk of our stock market becoming over-valued due to more funds, available from the Tier 2, "chasing" the same listed securities; and they investing pension funds in short term debt instruments due to the restrictions they currently have.

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    1. Neenyi,
      Thanks for the comment. On your understanding of the article, I am not sure I said that SSNIT and the private fund managers are investing in the same assets (stocks) and market (capital market) as in the activity having taken place already.

      I am rather cautioning that high information asymmetry and financial illiteracy could potentially eliminate any diversification benefits that could accrue as a result of dividing the pension fund management process into 3-tiers. This is because if the private fund managers are not aware of the investments undertaken by SSNIT, they are also likely to investment in such assets; in that case, the return on those assets both for SSNIT and the private fund managers would move in the same direction instead of moving in opposite directions as diversification requires. In other words, the assets would behave the same way instead of differently, so that they compensate each other in bad and good times. Please read it again but this time from a more theoretical point of view of diversification theory.

      Again, our investment environment is very small relatively. That is, we have very few investment assets in Ghana especially because our capital market is small. However, Pension funds are restricted by law from investing in some assets, this restriction even reduces the number of assets available to both SSNIT and the private managers. This makes it more likely that both managers are likely to invest in the same assets, which will result in the effect I am talking about.

      Your point on over-valuation of stocks is also valid and goes to support my point that we have very small numbers of stocks listed on our capital market. Such narrowness could lead to a shortage of stocks and prices rising.

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  2. Thanks for the clarification ... my point is that the import of your article means that they both end up investing, effectively, in similar assets due to information asymmetry which negates the diversification benefits ...

    My point to you is that although SSNIT is barred from making certain investments, it still gets to invest in securities and businesses that are not open to the private managers .. for e.g. the power sector (in which I work), Golden Beach Hotels, SSNIT also has many real estate investments, both residential and office space, which are not open to private managers .. these sorts of investments by SSNIT in my view make SSNIT more diversified compared to private managers.

    Also, in terms of information asymmetry between SSNIT and the private managers, SSNIT publishes most, if not all, of its investments in its annual reports and internal newsletters, even in the news sometimes etc so will need some more convincing on the information asymmetry risk you raise.

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    1. Neenyi,
      I am not sure you get the message I am trying to put across. I am not sure your assertion about SSNIT being a monopoly of some investments can be verified, less you supply evidence to that effect. If you do, you will find out that SSNIT is not a monopoly over these investments you have mentioned here; they may be the largest shareholders though. Now your point even makes my argument simplier. Have you asked yourself why SSNIT dominates these projects?? One of the reasons is that the private firms may be capital-scare but SSNIT has this chunk of funds. In effect, it tells you that with the 5% pension contributions which for many a Ghanaian would be less than GHS100, their investment choices are limited, perhaps a mutual fund is their best bet; but the problem is that most mutual funds also have a lot of shares in listed companies which are dominated by SSNIT. Thus, they may end up investing mostly in the same stocks as SSNIT would.

      Understanding the difference between asset allocation and stock selection is very important for understanding my article. I am not suggesting you don't. The article is specifically referring to asset allocation and not stock selection as in individual specific projects. At the asset level, an investor is dealing more with systematic risk unlike specific risk at the stock level. Anyway the function of asset allocation is done by the pension contributor and not the pension fund manager, so high illiteracy as is the case in Ghana could create this problem I am talking about. How many contributors are aware of SSNIT's investments??? I am not sure you can answer that accurately, let alone talk about their understanding of the risk and return profiles of these investments.

      Now let me come back to my point on systematic risk and asset allocation. If the contributors decide to invest in equities, the role of the pension fund manager is to do the stock selection (of companies listed). And don't forget that SSNIT has shares in about 50% of companies listed on the GSE. So, if equities are doing badly generally, it systematically affects the contributors' equity investments in the DC account and also his benefits in the DB account managed by SSNIT. It is this dominance effect of SSNIT of the stock market that can increase systematic risk and for that matter diversification risk.

      As indicated earlier, even at the stock selection level, there are diversification risk issues and my argument is valid.

      Your point of SSNIT publishing its investments is a good point but not exactly. This is because information economics will tell you that information asymmetry is not just about have access to the information but more importantly understanding the import of the information. So, publishing the investments does not necessarily mean that the information gap is bridged. Typically, policy studies will refer to this as the output-outcome gap. So my friend, my question to you is how many Ghanaians understand and will understand the risk and return profiles of these investments SSNIT makes?? I am not very sure you can answer this question at a 50% confidence interval or ...??? I can't either.

      Now think about the asset allocation and stock selection argument and come back. My solution is this....to reduce this diversification risk, financial innovation is the key, particularly product innovation. In this regard, we need to expand the set of investments available in the Ghanaian economy. Undertaking specific projects could be the way out

      Cheers!!!


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  3. Again consider this example, since the a member's total portfolio is the sum of the portfolios held by the individual managers; i.e. SSNIT and the private fund managers, if different managers are permitted to invest in the same assets, sometimes one manager may buy (say) bank shares, while another manager is selling bank shares. In this case the member incurs transactions costs for no overall benefit. I didn't even treat transactions cost in the article, adding that even complicates the problem. In addition, if two or more fund managers both decide to go overweight (underweight) in the same set of companies, the total fund can end up with a poorly diversified portfolio.

    Cheers!!!

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  4. Thanks for your response. In m y view, the underlying issue is not so much of diversification risk etc, but rather the real challenge, is the dearth of investment opportunity (a lack of financial innovation) which leaves investment entities such as SSNIT and Tier 2 firms with very little in terms of options to choose from creating the diversification risk you refer to. And tied up to that the asset allocations they must adhere to by law. But for me it's more of a situation of a lot of funds with very little investment opportunity. So yes, it undermines diversification, but it's the lack of investment opportunity and financial innovation i worry more about than diversification risk. A case in point is the likely over-valued nature of a few good stocks on the GSE for precisely the same reason.
    As for financial illiteracy as you call it, I don't think it's even an issue. A number of academic research papers demonstrate that so-called investment professionals are unable to beat the market. They so-called financial illiterates are better of owning an index fund with minimal fees ...

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