letter to the EF and Premiership about pension liabilities

1. The Pension Superfund Capital GP II Limited is registered in Guernsey under number 67461 with registered office at First
Floor, 10 Lefebvre Street, St Peter Port, Guernsey, GY1 2PE
1
The Football League Limited The Football Association Premier League Limited
EFL House Brunel Building
10-12 West Cliff 57 North Wharf Road
Preston, Lancashire London
PR1 8HU W2 1HQ
(“EFL”) (“Premier League”)
By email
11th
January 2024
FAO:
- EFL: Rick Parry (Chairman) and Trevor Birch (CEO)
- Premier League1
: Alison Brittain (Chairman) and Richard Masters (CEO)
Subject: The Football League Pension and Life Assurance Scheme Risk Transfer
Dear Rick, Trevor, Alison and Richard,
I write to you on behalf of Pension SuperFund Capital2
(“PSFC”). PSFC’s goal is to be the ‘one stop
pension shop’, and so take away your legacy pension obligations, allowing the EFL and Premier League
to focus on their core business of running football, whilst ensuring that members’ pension benefits are
paid in full.
UK football clubs have come to our attention, not least due to a number of high-profile changes of
control; and findings that clubs have fallen foul of UEFA’s Financial Sustainability regulations.
We offer an opportunity to provide full benefits to members with a very high degree of certainty, at a
significantly lower cost than an insurance buy-out.
We feel this is the correct time to engage, noting the latest triennial valuation is expected to have been
completed in H2 2023.
1. Our Understanding of the Situation
We understand there are two main pension schemes relevant to clubs in the EFL and Premier League:
- the Football League Limited Pension and Life Assurance Scheme (the “Scheme”); and
- the Professional Footballers Pension Scheme3
(the “PFP Scheme”).
Whilst this letter focuses on the Scheme, we would be very happy to engage under NDA to discuss the
position of the PFP Scheme also. Additionally, EFL appears to have a small defined benefit scheme
which we would also be happy to engage on as part of a wider solution.
The Scheme is a funded multi-employer defined benefit scheme. The previous actuarial valuation
showed a deficit of £27.6m (the “Pension Deficit”) which was shared amongst various clubs ranging
1 https://resources.premierleague.com/premierleague/document/2024/01/04/21175cfd-faa3-4b01-bbad-65894fead686/PL_Handbook_2023-
24_DIGITAL_04.01.24-final-.pdf.
2 Pension SuperFund Capital GP II Limited.
3 Created via a merger of Football League Limited Players' Non-contributory Cash Benefit Scheme and Football League Limited Players'
Retirement Income Scheme.

2. The Pension Superfund Capital GP II Limited is registered in Guernsey under number 67461 with registered office at First
Floor, 10 Lefebvre Street, St Peter Port, Guernsey, GY1 2PE
2
from the top of the Premier League to some non-League teams, albeit it is not possible to apportion a
specific share of the assets and liabilities of the Scheme to the various clubs.
2. Our Proposal relating to the Scheme
We expect the Pension Deficit will have reduced significantly or may even be in a surplus at the latest
triennial valuation. Even if the current valuation leads to a reduction or elimination of “deficit repair
payments”, the risk is not removed in perpetuity and the situation may easily reverse at future valuation
dates (pension liabilities have risen 5% in just the last couple of months) for reasons largely outside the
control of the trustees or sponsoring clubs. It is possible to transfer this risk to an insurance company,
but only for an additional premium - over and above what we can offer - of £20m or more in today’s
markets.
In addition, as a multi-employer scheme, each club is legally required to increase contributions
whenever a participating club exits the Scheme, most likely due to that club falling into financial
difficulties.
While the absolute sums paid per annum into the pension schemes by the Premier League clubs appear
relatively trivial compared with their TV revenues, payroll or gate receipts, the amounts are very
material in context for lower / non-league clubs.
We propose, with the support of both the EFL and the Premier League, to engage first with the ten
largest contributors to the Scheme. We hope that a solution with those clubs can be reached, to the
benefit of all parties – so de-risking every club in the football league and the Scheme members.
PSFC would provide a new solvent company that joins the Scheme and so underwrites the ‘full risks’
of the pension obligations on a “last man standing” basis to the benefit of all stakeholders and, most
importantly, the Scheme’s members (the “Proposal”). In addition PFSC will provide a new capital
buffer worth around 10% of the current liabilities. As well as removing the future cash demands on all
clubs, this will enable the trustees to adopt a new investment strategy, fully hedging their unrewarded
risks and generating surplus that can be used to enhance members’ benefits – most welcome in the
persistent inflation environment.
Given the impending conclusion on the triennial valuation process, now is the perfect time to engage in
this discussion
3. Benefits to football
De-risking Scheme members is to the benefit of all stakeholders. Alongside this, we envisage enactment
of Proposal will be a catalyst for positive news flow for clubs which participate.
For the relatively small cost to the larger clubs which engage with us, this will materially support some
now non-league entities such as Scarborough, Maidstone, Aldershot and Hereford who are a party to
the Scheme.
PSFC’s structures always provide a share of any upside with members of schemes where it takes on
‘full risk’. In addition to this sharing with members, we propose a further 5% of the upside is dedicated
to grass-roots football in the UK. This will provide a long term, low risk cash flow to UK grass-roots
football, bringing through the next generation who have been inspired by members of the Scheme.

3. The Pension Superfund Capital GP II Limited is registered in Guernsey under number 67461 with registered office at First
Floor, 10 Lefebvre Street, St Peter Port, Guernsey, GY1 2PE
3
4. Conclusion
We have our boards’ approvals to proceed with the Proposal. We look forward to engaging with you
further, both to ensure support for the Proposal and subsequently connect with relevant parties. We are
ready to provide documentation, including a price-lock guarantee, following provision of further
information.
We hope to work closely with you all to move the Scheme along the journey to a safe and secure home
with a solution that is good for members, good for clubs and good for the game.
Yours faithfully,
Edmund Truell
Director
Pension SuperFund Capital GP II Limited