Thread by @MikeOtsuka

@Sam_Marsh101 Here's an explanation of #USS's actions which I affirm & w/ which I think you might not take issue: #USS execs have given up on the hope of being able to issue a 2017 or 2018 valuation that tPR will deem acceptable. 1/

@Sam_Marsh101 But they remain strongly inclined to issue a valuation that tPR at least declares they're unlikely to take action against, even though they don't deem it acceptable. They're unwilling to go beyond that limit & enter into confrontation & dispute w/ tPR. 2/

@Sam_Marsh101 The just-submitted Rule 76 valuation, w/ its contribution rises encoded, stays within these limits. See this passage from the 11 Dec tPR letter👇. 3/

@Sam_Marsh101 Had #USS followed @Derek_Benstead's advice to issue the 2017 JEP 29.2% valuation w/ no triggers, they would at that point have entered into confrontation & dispute w/ tPR. Hence, their submission of the Rule 76 2017 valuation instead. 4/

@Sam_Marsh101 @Derek_Benstead In an attempt to continue to avoid entering into confrontation & dispute w/ tPR, #USS issued a 2018 valuation, since it was less difficult to get below 30% w/o encountering tPR resistance via 2018 rather than 2017 assumptions. 5/

@Sam_Marsh101 @Derek_Benstead #USS realises that even a 2018 valuation w/ contributions below 30% would encounter strong tPR resistance, given their assessment of the covenant as merely 'tending to strong'. 6/

@Sam_Marsh101 @Derek_Benstead They believe that only a 2018 valuation of < 30% w/ fairly onerous triggers of substantial contingent contributions might get tPR to the point where they declare they're unlikely to take action. 7/

@Sam_Marsh101 @Derek_Benstead The #USS execs also realise that employers would strong resist fairly onerous triggers of substantial contingent contributions. 8/

@Sam_Marsh101 @Derek_Benstead So, in agreement w/ you & Derek, I think the #USS execs tried to manipulate employers into signing on to such triggers via bait & switch plus extortion of the 2017 backstop. 9/

@Sam_Marsh101 @Derek_Benstead In so doing, they went too far & employers are now strongly pushing back, which explains the delay in #USS's issuing of their trigger contribution paper & their pushing the onus onto employers to devise the triggers. 10/

@Sam_Marsh101 @Derek_Benstead Politically speaking, this is the ground on which things are being fought: devising triggers to accompany a contribution level slightly less than 30% that neither tPR nor employers will too strongly resist. 11/

@Sam_Marsh101 @Derek_Benstead The above account, w/ which I suspect, Sam, you're largely in agreement, also explains why one would need to try to take the fairly extreme measures I mention in this blog 👇 in order to shift the ground to a No Detriment valuation. 12/12
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