USS complaint re the 2020 valuation
Many thanks to the 3783 of you who added your name to this letter. I have now finalised the list of signatories. If you have not added your name to the form, but wish to be kept up to date about developments at the USS and future similar efforts, then please add your details below.

I will let signatories know any response to the USS about our concerns. The USS complaints process is very slow, and the first stage can take up to four months.

Let me know if you have any comments or questions (

Neil Davies (22/01/2021)

Thank you for your interest in the 2020 USS valuation. We have serious concerns about the valuation proposed by the Trustees. We have written a letter below which details our concerns, which we plan to send to the USS under their complaints process (section 78 of the scheme rules).

A full version of the letter with appendix detailing specific concerns and questions can be found here:

Finally, please do feel free to share this with anyone who may be interested. The more people who co-sign, the better.

All the best,

Neil Davies


Dear USS Trustee,

cc Pensions Ombudsman, MPs on Work and Pensions Committee, UUK, USS Members

We are writing to collectively raise a complaint through the USS Internal Dispute Resolution procedure which operates under Section 78 of the USS Scheme rules.

We are seriously concerned that the changes to the USS valuation methodology proposed by the Trustee in the USS Valuation Consultation 2020 have little empirical or theoretical justification. The proposals could lead to the scheme overcharging USS members and employers including many UK universities.

Particular concerns relate to the proposed increases to the “level of prudence” compared to the 2018 valuation that the Trustee has not justified. Sensitivity analysis suggests this change increases the deficit by £7.4bn-£9.5bn. In addition there are potentially misleading and inaccurate statements in the documentation, and a lack of transparency over quantitative methods used to estimate key parameters in the valuation. There has been a consistent failure to meaningfully address concerns raised by stakeholders. The Valuation does not implement many of the proposals made by the Joint Expert Panel jointly convened by UCU and UUK.

The Trustee can resolve our complaint by publicly providing full details of:

1) evidence and justification for why the level of prudence should be increased from the previous valuation, or return it to its previous level (67th centile);
2) justification for setting the pre-retirement discount rate on a gilts+ basis, rather than the CPI+ basis recommended by the Joint Expert Panel, or use a CPI+ discount rate;
3) a robust account as to why a recovery period of 15-20 years as recommended by the first JEP report is not appropriate for the scheme, or revert to such a recovery period;
4) how the mortality assumptions have been updated in light of COVID-19;
5) how post-valuation experience of asset values has or will be accounted for in the 2020 valuation.
6) and how the proposed changes for the 2020 valuation would affect USS members who are differentiated by age, disability, gender, race, migrant status, or permanent or casualised employment.

We include an appendix which provides full details of our concerns. We look forward to your response.

Yours sincerely,


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