|In this newsletter:
Benchtest 09.2018, the role of RFIN, cost of regulation, powers of the regulator, impact of investment regulations and more...
Important notes and reminders
Tilman Friedrich's Industry Forum
Monthly Review of Portfolio Performance
to 30 September 2018
In September 2018 the average prudential balanced portfolio returned -2.00% (August 2018: 3.75%). Top performer is Investec (-1.45%), while Nam Asset (-2.97%) takes the bottom spot. For the 3-month period, Investment Solutions takes top spot, outperforming the ‘average’ by roughly 1.15%. On the other end of the scale Momentum underperformed the ‘average’ by 1.40%.
Investment regulations reduce your prospective pension by 27%
Namibian pension funds seem to have a serious problem and are unlikely to meet the implicit expectations of the retirement benefit one should expect them to provide. Typically pension funds are expected to produce an income replacement ratio of 2% per year of service. After having worked for 40 years, the expectation is that the fund member would receive a pension before commuting any portion of the retirement capital of 80% of the salary he earned just prior to retirement.
To achieve this implicit salary replacement ratio, pension fund assets should return roughly 6% above inflation, before asset manager fees. To achieve this return, it is assumed that funds would in practice invest around 75% in equity. The balance of the funds’ investments would be invested in other conventional asset classes (property, bonds and cash) in varying proportions depending on investment market conditions.
We know that investment regulations place certain constraints on asset managers and this may impact investment returns. Namibian funds are for example required to have invested in Namibia at least 45% of their assets by 31 March 2019, with a maximum of 10% that may be invested in dual listed shares. In practice this means that managers will invest around 48% plus in Namibia just to make sure that they do not expose their fund clients to any risk of penalties for being below 45%. Similarly, investment managers would in practice not invest more than 70% in equities in total to avoid any penalty for exceeding this cap. History corroborates this modus operandi of asset managers, who had on average invested 41% in Namibia at a time when the minimum was still set at 35%, given that an increase to 40% was anticipated already. The constraints placed on asset managers may produce lower returns on the various typical asset classes investment managers invest in, as they cannot freely invest in the highest yielding assets that may globally be available.
Assuming Namibian investment managers were to maintain maximum equity exposure of 72% as the highest yielding asset class, so as not to fall foul of the 75% cap too easily and assuming the asset classes would generate the returns they did from 1900 to 2016 (source – Prudential Investment Managers), table 1 shows that the managers should be able to generate a return of 6.3% before asset manager fees, typically around 0.8% or 5.5% after asset manager fees thus meeting the implicit return expectation of the traditional pension fund model.
If we now use the above table but bring in the minimum Namibian exposure of 47.6%, so as to not fall foul of the 45% minimum Namibian allocation, apply the average asset allocation of Namibian asset managers to Namibian equities and allocate the balance in accordance with the spread across all other regions and asset classes that the average manager currently applies, this will reduce investment returns by 21%...
To get the impact of the full story, read the Part 6 of the Monthly Review Portfolio Performance to 30 September 2018. Download the review here...
Regulator costs in perspective
In previous newsletters we expressed our concern about the cost of regulatory supervision and its consequence for retirement savings of pension fund members.
Having raised this with NAMFISA, NAMFISA undertook a great effort to compare Namibian levies with those of Botswana, the UK and SA concluding as follows:
Botswana – N$ 1.73 per member, per month, but does not take into account government subsidies.
South Africa – N$ 1.82 per member, per month.
Namibia – N$ 2.85 per member, per month.
United Kingdom – N$ 3.17 per member, per month.
As NAMFISA pointed out, smaller countries do lack the economies of scale of larger countries. Furthermore, mandates of regulators and their cost recovery formulas differ, making it very difficult to compare like with like. The question that needs to be asked is how much the costs of a regulator should be relative to its country’s economic parameters.
To explore this perspective we reported on a desk study of the regulatory costs in Australia compared to the Namibian regulatory costs in Benchtest newsletter of September 2018.
We have also carried out a desk study of the regulatory costs in the United Kingdom. The table below reflects the results of our desk studies.
We acknowledge that the above comparison of regulatory costs is quite simplistic as it does not take into account the fact that NAMFISA regulates other non-banking financial institutions such as medical aid funds, insurance companies, stock exchanges and asset managers that the other regulators do not regulate. We believe that it does give an indication of the relative proportions regulator levies represent in these countries though.
The table contains indicators that the cost of regulation in Namibia appears out of line with that in Australia and the UK. Given the likelihood that the cost of regulation in Namibia will increase further with the introduction of the FIM Act, the concern is warranted that this will have a negative impact on a pension fund member’s retirement outcome and the competitiveness of the Namibian economy.
Can NAMFISA CEO delegate powers to a staff member under the Pension Funds Act?
Stakeholders will have experienced NAMFISA staff sending out e-mails containing demands for action or information within normally pretty tight deadlines. Our reader who enquired how legitimate such demands and directives are, will undoubtedly not be the first and the only one to whom this occurred.
In this context it may be worth taking note of the following provisions of the Pension Funds Act:
1. Section 3, registrar and deputy registrar of pension funds: “The person appointed in terms of section 5 of the NAMFISA Act, 2001, as the chief executive officer of the NAMFISA shall be the registrar of pension funds.”
2. Section 3A, delegation of powers and assignment of duties: “The registrar may, subject to such conditions as he may determine, delegate or assign any power or duty assigned to him by this Act, to an officer or employee in the public service but shall not thereby be divested or relieved of a power or duty so delegated or assigned.
NAMFISA employees are not in ‘public service’ and it is hence our understanding that they cannot assume any powers or duties assigned to the registrar in terms of the PF Act.
What penalties may the registrar hand down under the Pension Funds Act?
Following a reader’s question concerning the legitimacy of penalties, the following should be noted:
The Benchmark Retirement Fund - Flagship of umbrella funds in Namibia
By Paul-Gordon, /Guidao-Oab, Benchmark Product Manager
Benchmark welcomes African Selection Management and PAAB
African Selection Management and the Public Accountants and Auditors Board will join the Benchmark Retirement Fund as from 1 November 2018. We express our sincere appreciation to these institutions for the trust and confidence in our ability to serve their staff as custodians of their retirement savings for many years to come! We heartily welcome African Selection Management and the PAAB and their staff and look forward to live up to our reputation and credo by administering your life savings in a manner that lets you sleep in peace!
News from RFS
RFS team visits Oude Rust Oord
As in previous years, a team of staff members visited the Oude Rust Oord for senior citizens on 1 October, international day of the aged and 55th anniversary of Oude Rust Oord, to hand out small food hampers to each one. It was quite emotional, sincere joy and appreciation exuding from many a resident’s face.
News from RFIN, the Retirement Funds Institute of Namibia
RFIN Annual General Meeting
RFIN held its annual general meeting and conference at The Dome in Swakopmund on 17 and 28 September. For those who missed the conference, RFIN prepared a synopsis of the papers that were delivered and panel discussions (the panel discussion on the FIM Bill was unfortunately not covered) that can be downloaded here...
News from the market
Head of NMG Namibia office resigns
Gert Grobler, general manager of NMG Namibia office resigned at the end of September to take up a senior position at Liberty Life Africa. Hein Klee, not unfamiliar investment expert at NMG will take care in Gert’s absence as acting general manager for the time being.
For those who may have missed the NMG news circular, download it here...
Staff changes at Alexander Forbes
After the recent resignation of Ramon Hansen, head of administration and consulting at AFFS, it was announced earlier this month that acting CEO will leave Alexander Forbes at the end of October. These resignations follow of the wake of the termination of the service of Jan Coetzee, previous CEO in July of last year.
For those who may have missed the Alexander Forbes news circular, download it here...
May the registrar refuse to register rules or amendment?
May death benefits be distributed later than 12 months after death?
In this case, PFA/WE/280/98NJ the complaint was by JH Jacobs, the executor of the deceased’s estate against Central Retirement Annuity Fund (the Fund) and Anne Satterwhite, spouse of deceased. JH Jacobs laid claim to the death benefit from the Fund comprising of a lump sum and an amount that was to be applied to purchase a 10 year pension.
An attorney acting on behalf of deceased’s wife Satterwhite lodged a claim for spouse’s maintenance against deceased’s estate. The executor thereupon requested the Fund to pay over the death benefit proceeds to the estate in order to consider the claim of the wife, which the Fund refused.
Following an investigation by the Fund into dependants it decided to award the full benefit to the deceased’s wife.
The fact of this case were as follows:
With reference to Dobie vs National Technikon Pension Fund, the adjudicator concluded that -
“The Private Security Sector Provident Fund is taking the owners of a Cape Town security company to court over a payment dispute. The case will be heard at the Western Cape High Court on September 13.
Several former employees of Proexec Security Network say they were cheated out of their hard-earned money. They are now relying on the fund to help them get justice. Until around September 2017, Proexec Security Network employed over 200 guards at buildings and apartment blocks in the Sea Point area. In May 2017, GroundUp spoke to a handful of workers who discovered that the company had not been paying their provident fund for several months. This despite the company making monthly deductions from the workers' salaries...”
Read the report by Barabara Maregele in News24 of 22 October 2018, here...
(for stakeholders of the retirement funds industry)
How to plan for dreadful retirement
“Regulation 28 is costing you 10% per annum” writes Magnus Heystek in this article. He coincidentally addresses the same concern we have raised in this newsletter of last month under the topic “Pension funds quo vadis?” Above, we continue dwelling on this topic expressing concern about the investment return eroding impact of regulation 28 in Namibia, as much as it seems to do in SA. And that is only the ‘tip of the iceberg’. Our FIM Bill in all its consequences will accelerate the erosion of pension savings and we agree with Magnus Hesytek’s conclusion “...So if you want your retirement to have any chance of being ‘carefree’ and ‘happy’ I suggest you urgently move what you can away from Reg28 funds in order to get a better chance of growing your retirement capital. Your current investment strategy of residential property and Reg 28 controlled pension funds is not going to end up well.”
Read the full article by Magnus Heystek in Moneyweb of 22 October 2018, here...
The biggest challenges to SA’s asset management industry
“...At the Morningstar Investment Conference in Cape Town on Thursday, a panel of senior industry executives discussed the biggest challenges in ensuring that this responsibility is met. Their views reflected an industry that is thinking critically about its future.
For Sangeeth Sewnath, deputy MD at Investec Asset Management, one of the greatest unknowns is how to deal with people living longer. He points out that British gerontologist Aubrey de Grey is predicting that some people alive today might live to be 1 000 years old...
The South African corporate sector has been damaged by a number of recent scandals, with Steinhoff and VBS being the most prominent. The MD of Nedgroup Investments, Nic Andrew, says that the asset management industry has to be critically aware of how these kinds of issues impact on investor trust...
The financial services industry has been the focus of a great deal of new regulation since the global financial crisis. In South Africa the new Twin Peaks regulatory regime has just been introduced, and the Retail Distribution Review (RDR) will have a meaningful impact on asset managers. For Tamryn Lamb, head of retail distribution at Allan Gray, it is a concern that uncertainty is created by how long it takes to roll these out. In addition, there is the risk of unintended consequences if the cost of complying with regulations makes it difficult for independent financial advisors to remain in business...
Looking at the long-term development of the industry, the CEO of RMI Investment Managers, Alida da Swardt, believes that its slow progress in terms of transformation is a substantial challenge. “When you look at the industry you are struck by the very low number of females and people of colour who are portfolio managers and investment professionals in general,” she points out. ..”
In Namibia, we are in a very similar situation and our industry faces very similar challenges, only with tons less capacity and capability to address the challenges.
Read the article by Patrick Cairns in Moneyweb of 19 October 2018, here...
SA investor’s growing love affair with offshore
but pay attention to fees
At the Morningstar forum for advisers, Victoria Reuvers said that “South Africans have had a fascination with offshore investing for decades, and this is likely to continue as investors become more comfortable investing offshore. Since 2001 the amount invested offshore has increased from R56 billion to R518 billion.
While political uncertainty has played a role in accelerating the flow of funds out of South Africa, the relaxation of exchange controls and the amnesty has had a material impact, says Victoria Reuvers, a senior portfolio manager with Morningstar Investment Management.
Investors, too, are simply broadening their investment horizons...
In a world of Trump economics, rising interest rates, trade wars, Brexit and rising populism, volatility is inevitable. “Focus on what you can control, not on what is out of your control,” says Reuvers. “This means focusing on company fundamentals. There are opportunities available – economic growth is still positive and inflation is manageable.”
On the other hand, valuations in the US are at all-time highs. In fact valuations on US companies are now higher than they were prior to the global financial crisis.
“There is a lot of optimism priced into the US market right now,” she adds, pointing out that there are other opportunities. “Regions marred by uncertainty – Japan, emerging markets, the UK – are less crowded and thus more attractive at the moment. The trick is not to follow the herd.”
Read the article by Sasha Planting in Moneyweb of 19 October 2018, here...
(for investors and business)
Namibia and SA budgets in a nut shell
If you are interested in a one-pager mid-term budget review of the Namibian Minister of Finance, download it here...
If you are interested in a one-pager mid-term budget review of the SA Minister of Finance, read the article by Ingé Lamprecht in Moneyweb of 25 October 2018, here...
How to wipe your personal information from Google, Facebook and Twitter
Facebook revealed last week that hackers got access to the sensitive personal information of as many as 30 million users, causing many to rush to delete their accounts and protect it from any further breaches. But Facebook is definitely not the only website on the internet that has a chock-full of data stored on you.
Even if you were one of the lucky Facebook accounts to be spared (you can check if you were affected here), it's possible that any of the other major websites, apps, and services - Amazon, Apple, Google, even Snapchat - could be next.
The only way to ensure your sensitive data can't be compromised is by removing your information from the internet entirely. In other words, if you're really worried about protecting your data from any future hacks...now is the time to delete your account.
Here's how to delete your accounts for many of the major websites, apps, and services:
By deleting your account, you will remove everything you've ever put on Facebook- profile information, photos, status updates, timeline posts - but it doesn't include messages sent via Facebook Messenger.
The photo sharing app does have an option to "temporarily disable" an account, but that option isn't a middle step before deletion like on other social media platforms. In other words, if you opt to temporarily disable your account, you can pick it up again later at your pleasure.
WhatsApp may be owned by Facebook, but it has a totally different way to delete your account. You can delete your WhatsApp account through the messaging app itself on your phone. Under "Account" in the Settings tab, you can delete your account easily by typing in your phone number. You can request a report of your account information, which takes about 3 days for WhatsApp to prepare. You should wait to actually receive your report before deleting your account, just to be sure.
Read how to delete your personal information from other platforms like Google, Snapchat and Twitter in this article by Palge Lesking in Business Insider of 18 October 2018, here...
Six low impact workouts that burn a ton of kilojoules
Low-impact training is a training or exercise method that minimises risk for external pounding, shearing, or jarring forces upon the body's joints," Taylor Hynes, a certified strength and conditioning coach and director of Player Performance and Wellness for the FC UNITED and Team ONE lacrosse clubs, told INSIDER. The good news? Hynes said low-impact does not mean low-intensity.
Hynes added that everyone can benefit from low-impact exercise, but that it's also important for people to incorporate high-impact workouts into their routine in order to maintain overall fitness.
"The primary drawback to low-impact training is that it is incomplete in the whole human athletic range of abilities," she said. "Only training one way reduces the body's intelligence in other areas. Your healthiest body can respond to all demands and recover to 100% without issue."
But Hynes said that it's a myth that high-impact workouts burn more kJs than low-impact ones. "
Stats of the day
From Capricorn Asset Management Daily Brief of 10 October 2018.