Considerations for actuaries when advising on commutation rates

This paper sets out the working party’s view that for a defined benefit pension scheme’s commutation rate the appropriate starting point should be to set it in line with the scheme’s cash equivalent transfer value basis. We recognise that there may be several reasons why an actuary in their advice may deviate from that starting point and we explore these in detail, giving our views on when deviation is and is not justified, noting that many common reasons used such as selection risk are often used without (in our view) adequate justification. We also cover frequency of review – our view is that commutation rates should be reviewed at least every 3 years and actuaries should consider performing a high-level review of commutation rates annually. We suggest that actuaries should consider proposing market-related commutation rates especially in periods of volatile market conditions. In terms of timing, there are good arguments to review commutation terms either following or during a valuation. Finally, we set out some considerations on how actuaries should present their advice, such as clearly setting out all the information required to take key decisions, following up with any actuarial certification in writing (if necessary) and illustrating the impact on members for changing commutation rates.