We are pleased to share with you the Q4’21 Ryan ALM Pension Monitor, which is a look at how pension assets and liabilities performed during 2021. As you will note, there are significant differences in the relationship of assets to liabilities based on the type of plan. Corporate pension plans use a FAS (ASC 715) AA corporate discount rate to value pension liabilities. Using this approach produces a -4.6% return for pension liabilities in 2021 for a pension plan with a 12-year duration. Despite lower returns among the average corporate plan due to their much greater fixed income exposure (P&I’s asset allocation survey of the top 1,000 plans), corporate plan assets outperformed plan liabilities by 12.5%.

Public and multiemployer plans that use the return on asset assumption (ROA) for their liability discount rate don’t benefit from the rising US interest rate environment, as liability growth is a static or plugged number. We are using 7.25% as the average discount rate among these plan types. Given the 7.3% return on liabilities in 2021 for plans using this ROA discounting methodology, assets only outperformed liabilities by 6.5% for public plans and 6.3% for multiemployer plans. As a reminder, liabilities are bond-like in nature and move daily with changes in the interest rate environment. The 39-year bull market for bonds crushed pension funding, as US interest rates plummeted causing the PV of liabilities to grow significantly. We may very well be entering a period of time that will prove beneficial to Pension America as liability growth could be muted as rates rise. But will public and multiemployer plans even notice?

Lastly, the primary objective for any pension plan should be to SECURE the promised benefits in a cost-efficient manner and with prudent risk. The only way that this can be achieved is through cash flow matching of assets versus the plan’s liability cash flows. Not focusing on or masking the true value of a plan’s liabilities makes this process nearly impossible.

US interest rates have been rising after touching historic lows at the onset of Covid-19. For the calendar year 2021, both short-term and long-term interest rates backed up. For corporate America’s pension systems this meant that plan liabilities sank -4.6% based on a 12-year duration. Viewed in combination with the average asset growth of +7.9% based on the P&I Asset allocation for the top 1,000 plans, pension assets outperformed plan liabilities by 12.5%. Wonderful! However, despite significantly stronger average returns for both public +13.8% and multiemployer plans +13.6% (given greater equity exposure) outperformance for the assets of these plans to plan liabilities was much more muted at 6.5% and 6.3%, respectively. Why the significant difference? Regrettably, the accounting rules permit both public and multiemployer plans to use the return on asset assumption (ROA) to value plan liabilities with the average plan using a 7.3% ROA.

If you are a public or multiemployer plan, you’ve skated through the last four decades thinking that a plan’s liabilities grew at a consistent rate – whatever the ROA was at the time. This masking of reality has been harmful, especially for many municipalities and states that have seen contribution expenses ratchet higher and higher. In a year like 2021 when assets growth was wonderful, while liability growth was negative, neither public nor multiemployer plans truly benefited to the extent that they should have because of these antiquated accounting rules. A rising interest rate environment may provide negative headwinds for plan assets, but the impact on plan liabilities should be even worse. But the truth may not be revealed!

The 39-year bull market for the US bonds crushed Pension America as the present value of future liabilities grew disproportionately when compared with plan assets. The dramatic increase in “cost” pushed many corporate sponsors to de-risk with the goal to freeze, terminate, and ultimately transfer plan liabilities. A small subset of corporate DB plans exists today compared to the early 1980s when more than 40% of the private labor force was covered by a traditional pension plan. The good news about rising interest rates is the impact on the present value of pension liabilities which shrink as rates rise improving a plan’s funded status all else being equal.

We’ve communicated often about these accounting irregularities. In fact, Ron Ryan wrote an award-winning book on the subject. Ultimately, we should have one accounting standard in the US to value pension liabilities. The rest of the world uses the accounting rules under IASB, which require a market valuation of assets and liabilities. Perhaps we don’t need to adopt the IASB standards, but it makes no sense to have two different accounting standards (FASB and GASB) in the US based on whether it is a public plan or a corporation. It is beyond time to take the blinders off. Let’s value a plan’s liabilities using a true market rate. It is only when we know the truth can we begin to formulate an appropriate response. We’ve closed our eyes during the longest bond bull market in history. We may just be opening our eyes in time to see what happens to plan liabilities when US rates rise as a secular trend. Forecasted weaker asset growth for the foreseeable future may not be the death knell that has been predicted when you might just have significantly negative liability growth at the same time.

I had been hearing rumors, as I’m sure that many of you were too, that the PBGC was going to present their “Final, Final Rules” as it relates to the ARPA implementation this week. We have been waiting roughly six months since they informed us of their “Interim, Final Rules” last July. Well, it is Friday, and it doesn’t look like we are going to get any update today, especially since the Office of Management and Budget (OMB) has not been provided with an update for their review. According to someone who I absolutely trust, an OMB review is a standard part of the rulemaking process. The updated guidance will not be released to the public until the OMB has reviewed those changes if any.

As we know, the Special Financial Assistance (SFA) grant has been approved for two plans to date. Another two dozen or so are in the queue, with many plans having had to submit revised applications. Most pension plans that used MPRA legislation to previously cut benefits have not filed an application for the SFA as of yet despite being eligible to do so since January 1st. Perhaps they are just waiting for these “final” rules to be published. Let’s hope that is the case.

Anyway, I’m not expecting a major update to this legislation. There may be some tinkering with the eligible list of investments for the SFA segregated assets, but that won’t dramatically improve this legislation. It will do more to destabilize the grant money’s original goal to “secure” benefits for as far out as possible. It is unlikely that the current discount rate will be reworked, as a change there could result in a substantial increase in the cost of the legislation, which is currently estimated at roughly $90-$95 billion. I do know that the legislation called for as simple a process as possible to file and receive grant money. Six months into this process and I think that it is safe to say that goal hasn’t been accomplished.

I’m writing this post from 35,000 feet as I return from a terrific Opal conference in Scottsdale, AZ. The conference was focused on public pension funds. It was great to be back among industry peers and friends who I have known for years. I was impressed with the panels and the questions from the audience. However, what struck me were the several comments expressed by leading plan sponsors that identified the “securing of the promised benefits” as THEIR primary focus. They couldn’t be more right! For years, we at Ryan ALM have claimed that the primary objective in managing defined benefit plans was to SECURE benefits at both reasonable costs and with prudent risk.

However, for most of my 40-years in the pension/investment industry, achieving the return on asset (ROA) objective has been the dominant pursuit by sponsors, consultants, actuaries, etc. This objective has led to a significant migration within asset classes from a more balanced fixed income/equity mix to one that is today dominated by equity and equity-like risk products. The volatility associated with this asset mix migration has ramped up as well. Furthermore, liquidity to meet benefit payments and expenses has become more challenging.

Yet, for two days I heard several public fund sponsors tell the audience that securing benefit payments was their most important objective. I nearly jumped out of my seat on those occasions. You see, it was just roughly 5-7 years ago that I could attend an Opal conference or any other sponsor’s conference and not hear the word LIABILITY once. Now you hear the mention of pension liabilities throughout the sessions. But what really has changed? Have plan sponsors, their consultants, and actuaries really changed the focus from one that is return centric to one that has liabilities squarely in the scope? Private pension plans certainly have, but they in many cases are trying to de-risk their plans with the goal of freezing, terminating, and eventually transferring their pension liability to an insurance company.

Public pension sponsors desperately want to preserve their DB pension systems and rightly so. These plans were designed to reward their participants for a job well done. The benefits paid help participants to achieve a dignified retirement. Failure to secure the funds necessary to meet these obligations would be disastrous. Yet, the change in asset allocation witnessed during the last 2+ decades creates an environment in which huge swings in funded status can be realized leading to significant increases in contribution expenses by the sponsoring entity. These increases have gotten the attention of taxpayers, many of whom don’t have a defined benefit plan to help them retire.

Today, we have seen significant improvement in funded ratios and funded status for many public pension plans. If securing the promised benefits is truly their new focus, it is time to take some risk off the table. The prospect of rising US interest rates will lead to challenging times for total return-oriented fixed income programs. But the total return is NOT the value in fixed income. Their value is the certainty of their cash flows! Use fixed income assets currently allocated to these programs to secure the promised benefits through a cash flow matching program that will move assets in lockstep with a plan’s specific liabilities while creating the liquidity necessary to meet the monthly payments. The current fixed income allocation might just secure the next 10 years or so of benefits after contributions, which helps create a bridge of security for your risk assets that can now grow unencumbered, as they are no longer a source of liquidity.

Don’t risk your improved funding. Secure those promised benefits for the participants who have represented your system with the utmost professionalism. They deserve to be able to sleep well at night knowing that no matter what happens within the volatile segments of our capital markets that their benefits have been protected for the foreseeable future.

The 18 Pension plans that received approval under MPRA to file for benefit relief have been slow to file their application for Special Financial Assistance (SFA). These plans were part of Priority Group 2 under the PBGC’s pecking order that permitted filing to begin on 1/1/22. To date, only Local 805 Pension and Retirement Plan has filed its application. Given that nearly 6 months have elapsed since the PBGC announced their “Interim Final Rules” in July 2021, one would think that applications would have been filed immediately upon the designated date. That clearly hasn’t been the case.

There is some speculation that more than one of these plans may not file for the SFA given the issues related to the legislation’s implementation and the likelihood that any SFA received would not be nearly sufficient to cover the prescribed 30-year time (until 2051) frame for the securing of benefits and expenses. These plans, using MPRA, have restructured their payouts to current beneficiaries and future retirees hoping to extend that life of the plan. A “reworking” of the benefits for plans that receive the SFA may create greater headaches than those that exist today. The truly sad part of this legislative failure is the expectation that benefits were to be restored to those participants who saw in many cases draconian cuts. A decision to not file for the SFA will be devastating news to the tens of thousands of plan participants that were celebrating the passage of ARPA last March.

My hope would be that any plan that has cut benefits under MPRA should gladly accept this grant from the Federal government to restore benefits. The SFA grant won’t likely cover more than 8-10 years of benefits, but it certainly buys time for future legislative efforts to bring effective change that actually accomplishes the intended action of protecting and preserving benefit payments for the next 30-years. These poor participants have gone above and beyond in their effort to help get legislation passed. It would be a slap in their face if a decision were made to forgo the receipt of this government largesse.

There are supporters and critics of almost any action or decision, especially in today’s hyperactive social media environment. The movement to consolidate downstate fire and police pension systems in Illinois is no exception. There were 649 police and fire plans merged for investment purposes into two large funds with about $15 billion in total AUM at the time of the consolidation. The primary motivation was to gain access to more investment opportunities because of scale, while also capturing some economies of scale in terms of fees, as many (roughly 65%) of these plans were <$20 million. I’m sure that there were other factors, as well.

What concerns me about this recent action has to do with asset allocation decisions based on the funded status of the individual systems that have been rolled up into these larger entities. Every plan’s funded status, contribution history, and unique liabilities should be factored into an asset allocation framework. However, that is not the case here. Every plan gets the same asset allocation depending on the pool that they invest in. How does this make sense? Asset allocation decisions should reflect the funded status. A plan that has a 90% funded ratio should NEVER have the same asset allocation as a plan that is 40% funded. Yet, that is precisely what will happen in Illinois.

Plans that are well funded should be able to reduce the risk inherent in the asset allocation, while those plans that are challenged from a funding standpoint should be given the opportunity to inject more risk into their asset allocation framework. We’ve seen what can happen to a well-funded plan when markets get hit, and they will again. Most public pension systems were overfunded in the late ’90s. Instead of securing the promised benefits and winning the battle, plans reduced their fixed income exposure and ramped up equity and alternative allocations. This decision proved disastrous, as two major market corrections decimated the funded status of Pension America during the ’00s leading to an explosion in contribution expenses as a direct result of this action.

We are once again at a point where public pension funds (and those of corporate America and multiemployer plans) have seen improvement in their funded status. It would be fiduciarily imprudent to not take risk off the table at this time. With equity valuations teetering at very expensive levels and US interest rates forecast to rise, perhaps rapidly so, markets could destabilize fairly quickly. It’s not like we haven’t seen this story play out before our very eyes. I applaud Illinois for trying to do something to sure up their unfunded police and fire plans, but not providing each system with the opportunity to tailor their plan’s asset allocation is a huge mistake. I wouldn’t want to be the municipal finance officer who has to inform their citizens that the 90+% funded plan is now at 65%.

Let’s talk about the Mega Millions Lottery, which is now offered in 45 US states and 2 additional territories. I wish that I were ready to announce that I’d won the $632 million from last night’s drawing, but alas, I’m not that lucky! However, the 2 winners will soon have to decide whether they take their winnings in a lump sum or in 26 annual payments. Most winners take the lump sum believing that they’ll generate a return greater than the annual growth rate factored into the future payouts. But, if they were to take the annual payments, how does the lottery system ensure that the proceeds are there when needed?

Let’s assume in this case that the winning ticket pays $10 million in total. The owner of the winning ticket is now going to own a series of 26 yearly payments that add up to $10 million. The lucky gal would receive the first payment for 2.5 percent of the total, or $250,000 (some taxes would be withheld from each check), two weeks after submitting the winning ticket. One year later, they would receive a check for 2.7 percent, or $260,000. Each year, the amount of the check goes up by a tenth of a percent with the last payment at 5 percent, or $500,000. In order to guarantee that the funds for all of these payments are available, the Lottery sponsor buys U.S. Treasury Bonds called STRIPS. (Separate Trading of Registered Interest and Principal of Securities). These are also known as zero-coupon bonds.

A zero-coupon bond pays a certain amount of money when it matures (future value). The longer the amount of time before the bond matures, the less it will cost you today (present value) to fund that future liability. Have you heard of any lottery systems going broke or being significantly underfunded? I haven’t! This is a “sleep well at night” strategy that doesn’t inject unnecessary volatility into the process. The liability is known (future payout) and the funding is secured using fixed income instruments. This is how defined benefit pensions (DB) were managed decades ago. Liabilities were known, monitored, and managed using defeasance and immunization strategies. The sponsoring entity wasn’t trying to achieve a return as an asset objective hoping that a collection of assets actually provided the “forecasted” return. Why do we live with that risk today?

The volatility in return patterns witnessed within DB plans since 2000 plays havoc with the contributions necessary to make up for any shortfall. As a reminder, most pension plans were well overfunded in the late ’90s. Instead of securing the victory, we saw asset allocation strategies reduce fixed income exposure, the only asset that resembles a plan’s liabilities, and instead, they injected more equity risk into the equation. This “strategy” failed miserably when markets got crushed on two different occasions during the ’00s (2000-02 and 2008). As a result, contribution expenses skyrocketed, and funded ratios plummeted. Not good!

Today, funded ratios have improved, but contribution expenses are still significantly elevated from 2000, as deficits are being amortized. Why did Pension America move away from the goal of securing the promised benefits with little risk toward a funding strategy that was predicated on taking more risk? Lottery systems are thriving in the US and around the world. On the other hand, defined benefit pension systems are under great pressure because of the costs associated with providing the promised benefit. Shouldn’t Pension America rethink the current strategy? Wouldn’t we be much better off securing a portion (Retired Lives Liability) of the promised benefits today? We believe that plans should bifurcate the asset allocation to Beta (defeased portfolio) and Alpha (risk/growth assets) buckets that serve to secure near-term funding needs while allowing the risk assets to grow unencumbered to meet future liabilities. Why would you ever want to use dividends and income from growth assets to fund assets? Let the Beta assets be the liquidity necessary to provide proper funding in securing benefits while reducing contribution costs and volatility.

Most plans have an allocation to fixed income already within the asset allocation. That exposure is likely to come under great pressure as the 39-year bull market for bonds ends. Convert your traditional return-seeking bond allocation to a cash flow matching strategy that will secure benefits and expenses for some # of years determined by the size of the current fixed income allocation. The remaining risk/growth assets can now grow unencumbered as they are no longer a source of liquidity. If interest rates go up, cash flow matching will enjoy lower funding costs while return-seeking bonds will receive a negative return. DB pension plans need to be protected and secured but managing them with a return focus instead of a liability focus only increases the odds that problems will present themselves sooner than later… remember the 2000-02 and 2008 corrections. It is time to get off this rollercoaster.

 

Since peaking at $68,789 per Bitcoin on 11/10/21, the price has fallen by more than 35% to just over $44,000 as I write this note. So much for the inflation hedge expectation and uncorrelated nature of this entity to other “asset” classes. Furthermore, it continues to trade like a “meme” stock. Oops!

Thank you, Alanis Morrissette, for coming up with a song title that is just perfect for today’s blog. Many industry practitioners have been complaining loudly, including us at Ryan ALM, that the discount rate used in the ARPA legislation (the 3rd segment under PPA + 200 bps) is wrong! This discount rate understates the “true” level of a plan’s liabilities. Instead of the one that was in the legislation, we should be using all three segments under PPA without any additional basis points penalty. As a result, the Special Financial Assistance (SFA) is much smaller than these struggling pension plans should be getting to fortify their funded status and preserve the promised benefits to pensioners through 2051.

However, many of the same industry voices are arguing that it is absolutely appropriate to use the return on asset assumption (ROA) to value a plan’s liabilities on an ongoing basis. HUH? Public pension systems operate under GASB accounting rules that permit this inappropriate accounting methodology instead of the discount rate required under FASB, which is much more of a true market-based rate. Multiemployer plans operate under a FASB hybrid system, with many (most?) using the ROA to “value” their plan’s liabilities. As a result, most multiemployer pension plans have funded ratios that are overstated, as their plan’s liabilities are understated in this historically low-interest-rate environment.

This action causes many problems, including the belief that the “ONLY” objective for multiemployer plans is to achieve the ROA! That is so wrong! The primary objective in managing a pension plan is to SECURE the promised benefits at a reasonable cost and with prudent risk. The pension objective is absolutely not to achieve a ROA target that in many cases has been determined through a “Goldilocks” approach. Pension plans of all types have been hurt by the significant decline in US interest rates since the bond bull market began in July 1982. As a result of this incredible fall in rates, the present value of plan liabilities has grown disproportionately relative to the benefit that the assets would have gained from a similar fall in rates, given the difference in the duration of a plan’s liabilities and its average fixed income exposure.

However, the absence of a true focus on pension liabilities, especially among public and multiemployer plans, masks this development. It doesn’t mean that the problem isn’t real, it does mean that many decisions with regard to asset allocation and benefits have been based on the wrong set of valuations. Now is the time for a re-thinking as an industry no matter what the accounting rules might suggest. After 39-years of US rates falling to incredibly low levels, we may finally be on the verge of seeing rates rise given the current inflationary environment. If rates rise, the present value of your plan’s liabilities will fall. In this scenario, a plan “wins” if assets outperform plan liabilities whether the targeted ROA is achieved or not. A 3% absolute return on pension assets outperforms a -3% on liabilities growth rate. It won’t take much of a backup in rates for a plan’s liabilities to dramatically underperform. 

Most pension systems have an average duration of their liabilities between 10-15 years depending on the maturity of the plan. In an environment in which US rates move 100 bps higher, a plan with a 12-year duration would see the present value of those liabilities decline by 12%, and with a YTM of liabilities (@ 2%) the pension plan experiences a -10% liability growth rate. A plan’s assets achieving only a 3% return would look heroic relative to liabilities despite not achieving the ROA’s hurdle. During the truly remarkable decline in rates, pension liabilities dramatically outperformed assets, even for those plans that regularly achieved or exceeded their return target.

So, is the SFA understated because of the wrong discount rate being used, or is the average multiemployer pension system’s funded ratio/status wrong because we are hiding behind accounting rules that mask the true story? Unfortunately, it is both! As an industry, can we finally commit to a TRUE accounting of our liabilities? Not having the truth means that actions taken are likely based on the wrong set of data which will invariably lead to the wrong conclusions. Ron Ryan wrote an award-winning book several years ago titled, “The U.S. Pension Crisis”. He lays the blame for our current situation on the “inappropriate accounting rules”. I couldn’t agree more. Pension America’s DB plans need to be protected and preserved, but that won’t happen until we truly know the scope of the funding issues.

As anyone knows who regularly follows this blog, Ryan ALM and I are huge fans of defined benefit pension plans (DB), and we work tirelessly trying to preserve and protect them. This doesn’t mean that we don’t appreciate defined contribution plans (DC) – we do – but supplemental (to DB plans) as savings vehicles. We also understand the motivation on the part of sponsors to migrate from DB plans (they don’t want to own the liability), but we still feel that it is an unfortunate trend. All that said, 2021 was a terrific year for sponsors of DB plans whether they were public, multiemployer, or private pensions. Capital markets and legislative initiatives combined to create an extremely favorable environment for Pension America. A year in which the average funded status improved, and in some cases, to levels not seen since the end of 1999. There are so many possible highlights to focus on, but I want to keep this post relatively short, so I’ll focus on the American Rescue Plan Act (ARPA), pension obligation bonds (POBs), equity markets, and US interest rates.

Legislation: It was extremely disappointing that the Butch Lewis Act (BLA) was never taken up by the US Senate in 2019, but we did get “Son of BLA” in the form of the American Rescue Pension Act (ARPA). This legislation was passed and signed into law in March. The Pension Benefit Guaranty Corporation (PBGC) was tasked with implementing this legislation. We are pleased to see following months of review, the “First Tier” applications are finally being approved (two so far). The Special Financial Assistance (SFA) will begin to flow to these plans soon. As a reminder, these grants are being given to multiemployer plans that are in Critical and Declining status and either currently insolvent or on the verge of insolvency. Importantly, benefits to participants that were cut under MPRA are to be reinstated if their pension plan receives an SFA grant.

Pension Obligation Bonds (POBs): Municipalities and states are aggressively using POBs to improve the economics of their pension systems. The historically low US interest-rate environment is providing a unique arbitrage opportunity. POBs have been around since the mid-’80s, but the pace at which they are being offered has established a new record. Only 2003 saw more $s committed to POBs than in 2021. Several entities, including the Center for Retirement Research at Boston College and the League of Municipalities, continue to be opposed to their use. We, at Ryan ALM, are supportive of POBs provided that the proceeds from these bond offerings are used to defease the plan’s Retired Lives Liability and NOT injected into the plan’s existing asset allocation, especially given current market fundamentals and valuations for both bonds and equities. Ryan ALM believes that POB proceeds should mirror the same asset allocation and objective of ARPA – secure the benefits! Plan Sponsors should invest POB proceeds in investment-grade fixed-income securities to defease projected benefits chronologically.

Equity Markets: The US stock market, as measured by the S&P 500 is up more than 27% YTD. This is the second-best annual return since 2013’s +32% result. Despite the wonderful performance result, all is not rosy. The Federal Reserve’s historic stimulus has potentially created an asset bubble rarely seen before. Equities have benefited tremendously since the Great Financial Crisis through this abundant liquidity (QE1, QE2, QE forever). Despite the stimulus, GDP growth has been modest at 2.3% per year since 2010. Wage growth, until recently has been weak with real annual increases of only 0.26% compared to 0.7% during the ’90s, and the labor market, as measured by the Labor Participation Rate, has shrunk to levels not seen since 1976 (<62%). Furthermore, roughly 85% of active equity managers have failed to beat the S&P 500 this year. A major contributor to this relative underperformance is the concentration within the S&P 500 to mega Technology stocks that continue to lead markets higher. This concentration in leadership tends to favor passive investment vehicles and 2021 is no exception. We should all be asking what the next 10-years will bring for equities.

US Interest Rates: The onset of Covid-19 brought the US economy to its knees in early 2020. As a result, US interest rates fell to levels not seen before (1.02% for the 30-year and 0.50% for the 10-year). As we began 2021 expectations were firmly established that rates would have to rise, and that expectation was quickly realized, as the US 30-year Treasury Bond saw its rate rise from 1.66% on the first trading day to 2.46% by early March. With inflation picking up to levels not seen since the early 1980s, most market participants felt that rates would continue to rise throughout the year and into 2022. Well, that didn’t happen, and as of today’s writing, the yield on the US 30-year Treasury sits below 2%. Will it remain there? Unlikely, as the Federal Reserve is expected to raise short rates at least 3 times next year. For pension America, any rise in rates helps reduce the present value of a plan’s liabilities, but it can be nasty for the plan’s fixed-income exposure if the allocation is focused on total return and long maturities.

So, in conclusion, 2021 was a terrific year for pensions. Now what? Given the improved funding and general expectations for more challenging environments for both equity and bond markets, plan sponsors should seriously consider reducing risk. It would be a travesty to waste all this good news by letting asset allocations remain static and subject to the whims of the markets. Use this unique time to reconfigure your fixed-income exposure to better manage assets versus plan liabilities. This reconfiguration will dramatically improve the plan’s liquidity while eliminating interest rate risk for the portion of the portfolio that will now focus on defeasing liabilities. This action will also buy time for the plan’s alpha assets (non-fixed income) to grow unencumbered, as they are no longer a source of liquidity to meet benefits and expenses. Furthermore, the buying of extra time allows markets to recover should we witness another major market correction. As we conclude 2021 we celebrate the great success enjoyed by Pension America. But, now is not the time to sit on one’s laurels.