Each employer's
"Preliminary Notice of Illinois Municipal Retirement Fund Contribution
Rate for Calendar Year 2011" will be available the week of April 5,
2010.
The notice shows
the actuarial required contribution rate, or "ARC," for 2011 for each
employer plan as well as the optional phase-in plan rate, if applicable.
Out of the 3,008 employers in the Regular plan, 58% will not be offered
a phase-in rate since their ARC is lower than the phase-in rate.
The higher ARC
rate was calculated by IMRF's actuaries and reflects the recovery
of your employer's actuarial accrued unfunded liability.
The lower rate,
the optional phase-in contribution rate, is based upon the IMRF Board
of Trustees' phase-in plan.
Beginning in
2010, employers who choose to contribute less than the ARC will be
required to record a net pension obligation (NPO) on their books for
the difference between what they actually contributed and what would
have been contributed using the ARC.
To help employers
determine their NPO, IMRF developed an Excel spreadsheet which will
assist you in doing the calculation. Please right click on the following
link to download the spreadsheet.
Employers have
until August 31, 2010, to select their 2011 contribution rate. Please
advise IMRF in writing (fax 630-368-5398, email coreylockwood@imrf.org,
or U.S. Postal mail) of your selection.
If IMRF does not receive a written response from an employer by August
31, 2010, we will assume the employer has selected the optional phase-in
rate.
While the phase-in
rate is lower and results in lower contributions currently, it does
result in higher contributions over the long term due to the additional
carrying costs on the resulting higher unfunded liability. IMRF encourages
employers who have the financial capability to contribute at the higher
level.
If an employer
is concerned with its ability to sustain a commitment to a higher
contribution level, it could select the lower phase-in rate for 2011
and make additional voluntary contributions to reduce its unfunded
liability. This would allow the employer to reduce its long term pension
costs while maintaining maximum flexibility to manage its contribution
rate in future years.
If an
employer wishes to contribute an amount above the optional phase-in
rate in connection with the normal monthly wage reporting process,
contact IMRF.
Employers should
carefully consider their selection of their 2011 contribution rate
since the rate selected for 2011 will impact the choices that will
be available in 2012.
Preliminary
2011 Rate Notice
We advised you that your employer’s “Preliminary Notice of
Illinois Municipal Retirement Fund Contribution Rate for Calendar Year
2011” was available. This notice provided two rates for each IMRF
plan your employer offers, e.g. Regular, Sheriff’s Law Enforcement
Personnel (“SLEP”) or Elected County Official (“ECO”)
plans, if applicable:
The
higher rate, the annual required contribution or “ARC,”
was calculated by IMRF’s actuaries and reflects the recovery of
your employer’s actuarial accrued unfunded liability (“Funding
Adjustment”) over 30 years for employers who can levy property
taxes and over 10 years for employers who cannot.
The
lower rate, the optional phase-in contribution rate, is based upon the
IMRF Board of Trustees’ decision.
If
you were not offered an optional phase-in rate
If an employer was not offered an optional phase-in contribution
rate for one of its plans, that means that the employer’s
ARC rate for that plan was lower than the optional phase-in rate.
Out of the 3,008 employers in the Regular plan, 58% were not offered
a phase-in rate since their ARC was lower than the phase-in rate.
If your rate includes ERI or SLEP enhancement
For most employers, the optional phase-in plan contribution rate
will be 10% higher than their 2010 contribution rate. Employers
who have an Early Retirement Incentive (ERI) or SLEP Enhancement
component of their contribution rate may have an increase more or
less than 10% because ERI and SLEP Enhancement costs are based on
a fixed liability and are not directly impacted by investment returns.
If
you were overfunded as of 12/31/08 but underfunded as of 12/31/09
Employers who were overfunded as of December 31, 2008, but were
underfunded as of December 31, 2009, and had a 2010 employer contribution
rate that was less than the full cost of the IMRF program will be
required to pay—at a minimum—the full cost of pension
service earned by its IMRF members in 2011. The average full cost
of current service for 2011 is 8.48% for the Regular plan, 12.88%
for SLEP, and 18.11% for ECO.
Individual employers’ full cost of 2011 current pension service
can vary from these averages. If an employer’s 2010 contribution
rate was less than the full cost of current service in 2010, the
employer will see their 2011 contribution rate increase to at least
the full cost of current service for 2011. In all cases these employers
will see at least a 10% increase in their 2011 employer contribution
rate.
Options Available for 2011 Employer
Contribution Rates
Employers may select:
The
optional phase-in employer rate,
The
ARC, or
A
rate between the optional phase-in rate and the ARC.
If
an employer wishes to contribute an amount above the optional phase-in
rate in connection with the normal monthly wage reporting process,
contact IMRF staff.
Employers
have until August 31, 2010, to select their 2011 contribution rate. Please
advise IMRF in writing (fax 630-368-5398, email coreylockwood@imrf.org,
or U.S. Postal mail) of your selection.
If
IMRF does not receive a written response from you by August 31, 2010,we will assume you have selected the optional phase-in rate.
This rate will be reflected on your “Final Notice of Illinois Municipal
Retirement Fund Contribution Rate for Calendar Year 2011,” which
will be available in November 2010.
If
you have the financial capability to select the higher ARC contribution
rate, IMRF encourages you to do so since higher contributions will lower
your pension costs over the long term. An employer’s actuarial accrued
unfunded liability is subject to interest charges based upon IMRF’s
actuarial assumed rate of return, currently 7.5%. By selecting the higher
ARC rate, you will reduce your unfunded balance more quickly thus reducing
the long-term carrying costs of the unfunded liability.
Choice
letters: Employers that are more than 120% funded
Approximately 62 employers are more than 120% funded on a market value
basis as of December 31, 2009. These employers have an additional option.
They may chose a lower minimum contribution rate calculated by IMRF.
I
n May, IMRF will mail these employers a “choice letter” explaining
this additional option.
Lump
sum payments
In addition to paying normal contributions through the monthly wage reporting
process, employers can make lump sum contributions to reduce their unfunded
liability.
While
these contributions can be made at any time throughout the year, from
the employer’s perspective it is most advantageous to make such
payments in December since IMRF grants interest on beginning of the calendar
year balances.
Any
employers thinking of making additional payments may want to contact IMRF
staff before doing so. (See Exhibit 1 of this
memorandum for detailed instructions on how to make additional contributions
using IMRF’s Electronic Funds Transfer system.)
Recording
net pension obligation
From a financial accounting perspective, an employer’s pension expense
is based on its ARC rate. The fact that an employer is allowed to contribute
something less than its ARC does not change the employer’s actual
pension cost.
Beginning in 2010, employers who choose to
contribute less than the ARC will be required by generally accepted governmental
accounting principles to record a net pension obligation (NPO) on their
books for the difference between what they actually contributed and what
would have been contributed using the ARC. GASB Statement 27 “Accounting
for Pensions by State and Local Governmental Employers” has a detailed
example on how to account for this difference.
To help employers determine their NPO, we developed
an Excel spreadsheet which will assist you in doing the calculation. Please
right click on the following link to download the spreadsheet.
Impact
of 2011 Choices on 2012 and Beyond
IMRF believes that the optional phase-in plan placed into effect for 2010
will extend beyond 2012. At the present time, IMRF intends to offer optional
phase-in rates for 2012 which will be capped at 10% in a manner similar
to 2010 and 2011. Thus for most employers, the 2012 optional phase-in
rate will be 10% higher than the 2011 contribution rate selected by the
employer. The rate an employer selects for 2011 will impact its
rate in 2012.
Assuming IMRF were to earn 7.5% on its investments
in 2010, it is estimated that the average ARC for the Regular plan would
increase approximately 1.7%.
As noted above, IMRF strongly encourages employers
with the financial ability to contribute at the higher ARC level because
it is cost beneficial. However, we realize there is a great deal of economic
uncertainty at this time and employers may be reluctant to commit to higher
contribution levels in 2011 in light of its impact on 2012 and later years.
If an employer is concerned with its ability
to sustain a commitment to a higher contribution level, it could select
the lower phase-in rate for 2011 and make additional voluntary contributions
to reduce its unfunded liability. This would allow the employer to reduce
its long term pension costs while maintaining maximum flexibility to manage
its contribution rate in future years.
IMRF’s
Annual Review of the Optional Phase-in Plan
When the IMRF Board adopted the optional phase-in plan at its February 27,
2009, meeting, it retained the right to review the phase-in plan annually
and to modify it based on future investment returns and other relevant factors.
At this time, IMRF believes that the phase-in plan will not be modified
for 2012 rate contribution purposes. If the IMRF Board believes that
the plan will have to be modified for 2012 rates, IMRF will promptly
communicate that information to employers. Since the current plan calls
for increasing an employer’s contribution rate 10% a year until
the rate reaches the ARC, the current phase-in plan has a built-in sunset
provision.
Questions
If you have any questions regarding the information presented in this
memorandum, please call or e-mail IMRF Employer Relations Audit Supervisor
Audrey Brown-Ryce at (630) 706-4246 or
arbrown-ryce@imrf.org or IMRF Employer Account Associate Analyst Corey
Lockwood at
(630) 706-4226 or coreylockwood@imrf.org.
IMRF Online provides
a brief summary of IMRF benefits and the adminstration of those benefits.
IMRF members'
and employers' rights and obligations are governed by
Article
7
of the Illinois Pension Code.
Statements in these publications are general,
and the Illinois state law governing IMRF is complex and specific.
If a
conflict arises between information in these publications and the law, all
decisions are based on the law.