***PSPRS Members: A first look at how the Arizona Legislature is proposing to reform PSPRS ***

Here is the draft legislative proposal for PSPRS pension reform that was posted to the Fraternal Order of Police website.  It is interesting that it says it is not for distribution, so I posted it verbatim here with format changes to fit this website.  I have not had a chance to digest it yet, but hopefully we can all figure out what it all means, but just remember that this is not final and nothing official, as far as I know, has come from the Arizona Legislature.  I would be interested in everyone's opinions.

DRAFT 5.0—FOR LEGISLATIVE & PFFA REVIEW TO ENSURE INCLUSION OF ALL CONCEPTS

CONFIDENTIAL: not for distribution, publication or attribution December 15, 2015

PSPRS Pension Reform Framework

Agreement Framework Language

The State of Arizona, the Professional Fire Fighters of Arizona, Arizona Highway Patrol Association, and the Phoenix Law Enforcement Association have engaged in policy discussions concerning reforms to the Public Safety Personnel Retirement System (PSPRS). The parties have reached the below framework for a tentative agreement on both retroactive and prospective reforms. It is understood that this agreement framework is subject to formalization through the development of state legislation and a subsequent voter initiative.

A.        The current Tier 1 and Tier 2 retirement plans will be modified as follows:

  1. PBI / COLA Reform:

a.         For all Tier 1 and Tier 2 members, the existing Permanent Benefit Increase (PBI) structure shall be eliminated and replaced with

a Cost of Living Adjustment (COLA) that is:

i) A compounding COLA based on regional CPI (annual change in the U.S. Bureau of Labor Statistics CPI-U for Phoenix-Mesa, AZ), with a cap of 2%

ii) Actuarially accounted for in advance as part of normal cost determination

iii) In the first year of retirement, the COLA will be prorated based on the date of retirement

b.         The above COLA provision shall be included as a severable element in the proposed enacting legislation and shall be effectuated upon passage of a separate voter-approved constitutional amendment approving a one-time opening of the Pension Clause in the Arizona State Constitution.

  2.       Defined-Contribution Plan for Tier 2 participants hired between January 1, 2012 and December 31, 2016:

Catch-Up Provision: In order to achieve equity between employees hired prior to January 1, 2012 (who have a deferred retirement option plan available to them), employees hired in the new Tier 3 retirement (who have a defined contribution (DC) component, as described in the following Section B), and employees hired between January 1, 2012 and the effective date of Tier 3 benefits (Tier “2b” members, who have neither the option of the DROPor DC plan), a defined contribution account will be established for Tier 2b members not enrolled in Social Security with the following contribution rates:

a.         For a member hired in 2012, a required employer contribution of 4% of the member’s regular compensation and a required contribution by the member of a minimum of 3% of that member’s regular compensation for seven (7) years, after which point the employer and employee contributions to the Tier 2 defined contribution plan are shared equally at 50/50 at the same rates as Tier 3, Option 1 (PSPRS Tier 3 Hybrid).

b.         For a member hired in 2013, a required employer contribution of 4% of the member’s regular compensation and a required contribution by the member of a minimum of 3% of that member’s regular compensation for six (6) years, after which point the employer and employee contributions to the Tier 2 defined contribution plan are shared equally at 50/50 at the same rates as Tier 3, Option 1 (PSPRS Tier 3 Hybrid).

c.          For a member hired in 2014, a required employer contribution of 4% of the member’s regular compensation and a required contribution by the member of a minimum of 3% of that member’s regular compensation for five (5) years, after which point the employer and employee contributions to the Tier 2 defined contribution plan are shared equally at 50/50 at the same rates as Tier 3, Option 1 (PSPRS Tier 3 Hybrid).

d.         For a member hired in 2015, a required employer contribution of 4% of the member’s regular compensation and a required contribution by the member of a minimum of 3% of that member’s regular compensation for four (4) years, after which point the employer and employee contributions to the Tier 2 defined contribution plan are shared equally at 50/50 at the same rates as Tier 3, Option 1 (PSPRS Tier 3 Hybrid).

e.                     For a member hired in 2016, a required employer contribution of 4% of the member’s regular compensation and a required contribution by the member of a minimum of 3% of that member’s regular compensation for three (3) years, after which point the employer and employee contributions to the Tier 2 defined contribution plan are shared equally at 50/50 at the same rates as Tier 3, Option 1 (PSPRS Tier 3 Hybrid).

f. A member is fully vested in the defined-contribution plan after 10 years of service, with employer contributions vesting at a rate of 10% per year, with the exception of a disability retirement, in which case there would be immediate 100% vesting.

Tier 2 participants hired between January 1, 2012 and December 31, 2016 will not be eligible for this benefit if, for any reason, these members become eligible for a DROP or similar benefit. If deemed ineligible, all employer contributions made pursuant to this catch-up provision must refunded to the employer.

B.        All employees hired on or after January 1, 2017, shall have the option of electing, within 90 days of employment, to participate in either the Tier 3 Hybrid retirement plan or the Tier 3 Defined Contribution plan. Members who do not make an affirmative election will be placed in the Defined Contribution plan, as  described below.

1. Option 1 (PSPRS Tier 3 Hybrid)

A new PSPRS Tier 3 Hybrid retirement plan for Police and Fire employees that includes the following elements:

a. Defined-Benefit Pension:

Defined-benefit pension benefit based upon years of credited service at retirement or termination, calculated as the member’s final average compensation times the number of whole and fractional years of credited service times the following:

i) 2.50% if the member has at least 25.00 years of

 credited service.

ii) 2.25% if the member has at least 22.00 years of credited service but not more than 24.99 years of credited service.

iii) 2.00% if the member has at least 19.00 years of credited service but not more than 21.99 years of credited service.

iv) 1.75% if the member has at least 17.00 years of credited service but not more than 18.99 years of credited service.

v) 1.50% if the member has at least 15.00 years of credited service but not more than 16.99 years of credited service.

b. Defined-Contribution Plan for Non-Social Security

Employers:

Those Tier 3 Hybrid Plan members not enrolled in Social Security,shall be provided with a defined-contribution plan with contributions consisting of:

i) A required employer contribution of 3% of the 

member’s regular pay; and

ii) A required contribution by the member of a minimum of 3% of that member’s regular pay. Employees may elect to increase the employee’s contribution up to the annual limits established by the IRS.

iii) A member is fully vested in the defined-contribution plan after 10 years of service, with employer contributions vesting at a rate of 10% per year, with the exception of a disability retirement, in which case there would be immediate 100% vesting.

c. Equal Cost Sharing

i) Employers and Tier 3 Hybrid Plan employees shall equally share all normal costs, future unfunded liability amortization costs, and administrative costs on a 50/50 basis.

ii) There shall be no caps on employer or employee

contribution rates.

iii) All Tier 3 Hybrid Plan normal costs, unfunded liability amortization costs, and administrative costs shall be calculated on the basis of just Tier 3 in isolation from all other PSPRS tiers and shall not be construed to include any normal costs, unfunded liability amortization costs, and administrative costs associated with any other PSPRS tier.

iv) Pursuant to the above, members enrolled in the Tier 3 Hybrid Plan will only be contributing to any future unfundedliabilities on the obligations of the participants in the Tier 3 Hybrid Plan and no other PSPRS tier.

d. Cost of Living Adjustment

i) Compounding COLA based on regional CPI (annual change in the U.S. Bureau of Labor Statistics CPI-U for Phoenix-Mesa, AZ), with cap of 2.0%, unless the funded ratio of the plan falls below 90%. In years the plan falls below this funding threshold, the cap will be adjusted as follows:

(1) If funded ratio of the plan (per the most recent actuarial valuation) is between 80-89.99%., the cap is reduced to 1.5%

(2) If funded ratio of the plan (per the most recent actuarial valuation) is between 70-79.99%., the cap is reduced to 1.0%

(3) No COLA will be issued in any year in which the funded ratio of the plan (per the most recent actuarial valuation) is below 70%

ii) COLAs begin the first calendar year after the retiree reaches the 7th anniversary of their retirement date (or at age 60 regardless of whether the 7 year delay was met)

e. Minimum Benefit Eligibility Age

i) The minimum benefit eligibility age for an unreduced pension benefit will be age 55, with 25 years of credited service.

ii) The minimum benefit eligibility age for an actuarially equivalent pension benefit will be age 52.5, with 25 years of credited service.

f. 80% cap

i) The maximum pension benefit will be 80% of an employee's final average salary (same as Tier 2 status quo =2.5% x 32 years of credited service)

g. Final Average Salary Determination

i) Five-year final average salary is defined as five consecutive years within the last 20 completed years of credited service that yield the highest average.

ii) Overtime earned and credited towards final average salary is counted as pensionable that is subject to the employee/employer contribution rate.

iii) Note: FLSA pay is not considered overtime (56 hour standard work-week  for firefighters).

h. Cap on Pensionable Pay

i) Beginning on January 1, 2017, the annual compensation of each member taken into account for purposes of the system shall not exceed $110,000.

ii) To account for inflation, PSPRS will calculate and publish (via a report to  the legislature) the growth in salary scales annually, and the Pensionable Salary Cap will be indexed every three years in order to maintain pace with inflation, in the following manner:

(1) The cap will increase by the percentage increase in average of the pay scale for active employees below the rank of Police Sergeant and Fire Captain.

(2) In determining the adjustment to the cap, the percentage increase in average pay scale will be calculated as weighted by employer’s payroll relative percentage of total payroll. For example, consider a plan with two employers: in a given year Phoenix represents 70% of total payroll in the plan and Peoria represents 30%. If from one year to the next Phoenix’s pay scale for active employees below the rank of Police Sergeant and Fire Captain increases 2% and Peoria’s increases 10%, a weighted average would mean increasing the cap 4.4%; ((2%*70%)+(10%*30%)) = 4.4%.

i. Vesting

i) Defined-Benefit Vesting: A member is fully vested in the defined-benefit pension component of the Tier 3 Hybrid after 15 years of service

ii) Defined-Contribution Vesting: A member participating in the Non-Social Security defined-contribution component of the Tier 3 Hybrid plan is fully vested in the defined contribution plan after 10 years of service, with employer contributions vesting at a rate of 10% per year, with the exception of a disability retirement, in which case there would be immediate 100% vesting.

j. Lateral Hires

i) Employees may change employment between member agencies, retaining all benefits earned and with no negative impacts to their future benefit accrual, as long as there is no separation of service greater than 180 days. Approved leaves of absences consistent with existing leave policies are not

subject to the 180-day period. Each employing agency will be individually  responsible to liabilities accrued during the employee’s tenure of service with that respective agency.

2. Option 2 (PSPRS Tier 3 Defined-Contribution Plan)

a. Tier 3 Defined Contribution Plan members shall be provided with a defined-contribution plan with contributions consisting of:

i) A required employer contribution of 9% of the member’s regular pay; and

ii) A required contribution by the member of a minimum of 9% of that member’s regular pay. Employees may elect to increase the employee’s contribution up to the annual limits established by the IRS.

iii) A member is fully vested in the defined-contribution plan after 10 years of service, with employer contributions vesting at a rate of 10% per year, with the exception of a disability retirement, in which case there would be immediate 100% vesting.

b. [ALL PARTIES ARE AGREE THAT WE NEED TO DETERMINE APPROACH FOR HANDLING DISABILITY FOR DC TIER MEMBERS—REASON FOUNDATION IS RESEARCHING OPTIONS]

C. PSPRS Governance Reforms

1.         The appointment and composition of the PSPRS Board of Trustees will reflect the cost-sharing/risk-sharing of the Tier 3 retirement formula.

2.         OTHER REFORMS TBD, currently in development by PSPRS Governance Reform Working Group

D. Miscellaneous Additional Reforms

1.         All new hires after January 1, 2017 shall be required to make a positive and irrevocable election between either the Tier 3 Hybrid Plan or Tier 3 Defined Contribution Plan within 90 days of employment. Any employee failing to make an election within 90 will be deemed to have elected the Tier 3 Defined Contribution Plan

2.         At no time will any PSPRS employer’s annual payment to PSPRS be less than their share of actuarially determined normal cost. No credits against normal cost shall be factored in to annual employer contributions.

3.         At no time will any PSPRS employee’s contributions to PSPRS be less than their share of actuarially determined normal cost. No credits against normal cost shall be factored in to employee contributions.

4.         This proposal requires that for existing Tier 1 and Tier 2 employees, the member contribution rate will be applied only to pensionable pay for those remaining in the current tiers, while the total employer contribution rate (normal cost, plus unfunded liability costs) will be applied to total pensionable pay of employees in all tiers.

5.         For all Defined-Contribution benefits described above, reasonable safeguards will be placed upon the accounts to ensure adequate long-term financial security. Such safeguards are, but not limited to, prohibitions on borrowing against assets, prohibition on day trading activities, limited quantity of funds to invest in, options available for target-date funds and automatic rebalancing, member education, and advice lines.

6.         Any future benefit increase shall be fully paid in the year of enactment and cannot be amortized over any period of years. The cost of the benefit should be calculated using a risk-free rate of return, using the Ten-Year Treasury Constant Maturity rate, for both the discount rate and the expected rate of return on assets, and the plan actuary should calculate the cost of the benefits using a mortality table published the year the benefit change is adopted (not an older table with adjustments made up to the present year).

E. APPENDIX

1.         For the proposes of actuarially modeling these changes, Reason Foundation is using the assumptions of the plan, plus the following additional assumptions outside the plan:

2.         5% of Tier 3 members will select the Tier 3 Defined Contribution Plan annually.

3.         65% of members are in plans that do not offer Social Security, and thus 65% of Tier 2 and Tier 3 members qualify for the 3% employer contribution rate to a DC plan.

4.         For the proposes of measuring the cost/savings, and changes to employer risks:

5.         The PSPRS baseline should include the costs of the current PBI design (up to 4%) in the calculation of baseline normal cost.

6.         Nothing about the proposed changes should be constructed as closing the plan or changing the amortization schedule. Changes to current employee benefits are only related to reducing the COLA to a maximum of 2% and adding a defined-contribution “catch-up provision” for employees hired after January 1, 2012, as described in Section A(2) above. Changes to future employee benefits involve a change to the defined-benefit multiplier design, benefit eligibility, COLA benefits having a 7-year waiting period (or until age 60) before they begin, and an employee option to select a 100% definedcontribution-only plan. Changes to future hire employer costs change the employer percentage paid on any future Tier 3 unfunded liability amortization costs (reducing it to a 50/50 share with employees), but not the amortization schedule itself.

7.         For the purposes of measuring changes to benefits:

8.         Projections of current benefits offered to benefits under the proposed changes should include Social Security benefits for eligible employees, whether calculating projected annuities or replacement rates.

9.         Projections of the value of defined-contribution funds should assume a rate of return 50 basis points below the plan’s expected rate of return, i.e. a 7% rate of return for the defined-contribution under the current plan assumptions.

PSPRS investment returns through November 2015

The following table shows PSPRS' investment returns, gross of fees*, versus the Russell 3000 for November 2015, the fifth month of the current fiscal year (FY), with the fiscal year end 2014 and 2015 returns included for comparison:

Report	PSPRS	PSPRS	Russell 3000	Russell 3000
Date	Month End	Fiscal YTD	Month End	Fiscal YTD
6/30/2014	0.78%	13.82%	2.51%	25.22%
6/30/2015	-0.73%	4.21%	-1.67%	7.29%
7/31/2015	0.13%	0.13%	1.67%	1.67%
8/30/2015	-1.43%	-1.31%	-6.04%	-4.47%
9/30/2015	-1.02%	-2.31%	-2.91%	-7.25%
10/31/2015	1.95%	-0.36%	7.33%	0.08%
11/30/2015	0.37%	0.09%	0.55%	0.63%

There is usually about a two-month lag in PSPRS reporting its investment returns.  PSPRS's Board of Trustees did not have a regular meeting in December 2015 nor did they include October 2015 returns in this month's meeting materials, so the returns for the month of October are extrapolated from the September and November returns.  The pattern continues with PSPRS returns.  When the Russell 3000 is negative, PSPRS' losses are less, but when the Russell 3000 gains, PSPRS lags those positive returns.  PSPRS is always happy to remind everyone how well their investment strategy manages volatility.  However, volatility works both on the upside and the downside.  It is great that PSPRS suffered only 23.67% and 35.00% of the losses in August and September, respectively, but PSPRS captured only 26.60% of the gain in October. 

Once again, I do not see how PSPRS can ever earn its expected rate of return, except when there is a bull market showing double-digit gains.  As of November PSPRS has only earned 14.29% of  Russell 3000's 0.63%.  The pattern in the past two fiscal years has been for PSPRS to earn between 55% to 60% of the Russell 3000.  If PSPRS consistently earned 60% of the Russell 3000, the Russell 3000 would need to average 12.5% returns for PSPRS to consistently earn its ERR of 7.5%. As of yesterday (January 19, 2016), the Russell 3000 is down 8.59% in 2016 with what appears to be another big loss coming today.  Is this the start of another financial downturn?  Who knows?  Though I think it is probably safe to assume that PSPRS is going to see a loss for the year, and no COLA's will be paid to retirees next fiscal year.

* Returns, gross of fees, are used because PSPRS usually does not report returns, net of fees paid to outside agencies, except on the final report of the fiscal year.  Returns, gross of fees, are used in the table for consistency.  The past two years fees have reduced the final annual reported return by about a half percent.  Returns, net of fees, were 13.28% and 3.68% for fiscal years 2014 and 2015, respectively.

If you don't understand how lucky you are to have them taking care of your retirement, PSPRS has a guy to help paint a picture for you

If you were not aware,  those social media-savvy pros responsible for our retirements have both a Twitter account and a Facebook page.  Check them out if you'd like, unless, of course, you're expecting any updates on things that might interest, concern, or affect you.  The last relevant tweet dates back to August 2015, and the last post on the Facebook page dates back to May 2015.  However, I did find a link on their Twitter account to this opinion piece by Grant Wood, "Why Millenial should care about retirement security," that was published in the December 15, 2015 Arizona Capitol Times.

Normally I would not feel compelled to comment on such a silly piece, but PSPRS thought highly enough of it to share it with its 40 followers.  This is despite the fact that Mr. Wood's primary contention about defined benefit pensions is false:

Defined benefit pension plans like ASRS provide a much more secure retirement plan as they don’t rely on the stock market for their success the way defined contribution plans, or 401Ks, do.

He writes about his retired public employee grandparents who are now safe and secure with their Arizona State Retirement System (ASRS) benefits.  He ends his piece with what is meant to be a rallying cry to fight the moneyed interests he feels are trying to destroy the futures of people like his grandparents:

Wall Street interests will continue to attack public pensions this coming year as they have been for so many to switch employees out of defined benefit public pension systems and into defined contribution 401Ks, where they make the money.

Attempts like this, and similar to Proposition 487 in 2014, to switch new or current employees into defined contribution systems and out of stable defined benefit systems like ASRS threaten secure systems and can cost taxpayers millions. I won’t let this happen to my family and will stand to protect ASRS and public pensions in my state. Will you?

At 23 years old with his new college degree, Mr. Wood seems full of righteous passion to make the world a better place, which no one should discourage, and it is not my intention to mock or criticize him. However, as his elder I have a responsibility to pull him back to reality.  I can start by directing him to ASRS' asset allocation page, which shows where it invests and earns the income to pay his grandparents' benefits.  Here is ASRS' portfolio breakdown:

US Equity	26%
Non-US Equity	24%
Private Equity	8%
US Fixed Income	15%
Private Debt	10%
Real Estate	10%
Commodities	2%

So defined benefit pensions don't rely on the stock market?  Not according to ASRS, which is half invested in equity markets.  Furthermore, all the investments require the use of Wall Street firms to facilitate investment in the various asset classes.

I will give Mr. Wood more credence for his argument that Wall Street would prefer savers to be in defined contribution (DC) pensions versus defined benefit (DB) pensions.  This is because fees tend to be higher in DC pensions.  This excellent brief from the Center for Retirement Research (CRR) at Boston College gives an excellent comparison of DB and DC plans as well as good information on fees. Lower fees for DB plans are most likely due to economies of scale.  A large investor like ASRS or PSPRS can bargain and shop around for lower management fees.  The individual investor cannot and is stuck with whatever investment firm(s) his employer chooses to manage the employer's DC plan.  So, there is something to Mr. Woods' argument, but let's look more closely at what Wall Street makes off DB pensions.

PSPRS, my not-so-stable pension, earned 4.21%, gross of fees, last fiscal year.  Net of fees, PSPRS earned 3.68%, so 0.53% was paid in management fees.  According to the 2015 annual report, PSPRS paid a total of $129.1 million to various asset managers.  We should keep in mind that was what Wall Street managers earned from just a single pension plan in Arizona, which is not even the largest in the state.  The aforementioned CRR brief says that the median index equity fund has a fee of 0.44% and the median bond fund is 0.86%.  An 80/20 mix of stocks/bonds would give an annual fee to a DC pension investor of 0.524%, comparable to what PSPRS paid out in fees for its portfolio, albeit one that is much more complex.  Regardless, if we work off the premise that individual DC pension investors should allocate their money in low-fee index funds, as many financial advisers recommend, this is a fair comparison and shows that disciplined, long-term DC investors can pay fees close to what DB pension managers pay to invest for them.

However, the key point Mr. Wood misses is the real allure DB pensions have for Wall Street and why they would never want them to be eliminated.  DB pensions bring in billions of dollars that are held captive by entities out of the control of the individual whose retirement they are meant to fund.  If DB pensions were eliminated, those dollars would revert back to the individuals and employers with no guarantee that they would then be placed entirely into DC pensions since there is no legal requirement to contribute to your own retirement, except for Social Security, which Wall Street cannot touch.  What percentage of those billions in DB pension contributions would voluntarily end up in DC pensions is open to speculation, but it would certainly not be 100%.  I would guess that it would be drastically less.  How much captive money would Wall Street be willing to give up from DB pensions in order to possibly make more in fees from voluntary DC pensions.

Employees contributed about $215 million to the combined plans managed by PSPRS last fiscal year.  Employers contributed about $547 million.  If employees put 70% of these DB contributions into a DC plan, and employers matched that 100%, only $301 million would go to Wall Street to invest versus $762 million.  I think they would rather take the sure thing provided by DB pensions than risk employees and employers spending that otherwise captive money on other things.  After all, they don't care whether anyone or any organization makes money, only that they get their cut (or vig, as the case may be), which they cannot get if the money is not placed with them in the first place.  Ideally, they would probably like both DB and DC pensions to be as large as possible.  The more the merrier, but I think in the end their preference would be for DB pensions over DC pensions.

Defined benefit pensions are a mess today because of the ignorance and naivete expressed by Mr. Wood in his opinion piece.  Defined benefit pensions do not magically produce retirement income.  They have to follow the laws of finance and have to be managed with the overriding principle that anything you promise for the future has to be paid for in advance.  If not, taxpayers and future employees are stuck with the unpaid bill.  Mr. Wood can be thankful that his  grandparents are members of ASRS, a pension system much better managed than PSPRS, and can enjoy their well-earned retirement without the anxiety PSPRS members are having to deal with now.

If Mr. Wood wants to get involved, he should acknowledge and work to prevent the same errors, borne of greed, selfishness, and ignorance, that have so crippled DB pensions.  Perhaps he could work to find out how to consolidate the DC plans throughout the state so that they can lower fees for members.  For example why does the City of Tucson, Pima County, Pima Community College, the University of Arizona, and even Raytheon for that matter, each have their own DC plan?  Wouldn't it be better for them negotiate as one large group with Fidelity, ICMA, Nationwide, TIAA-CREF, et al. and get the lowest  fees for their members and the best investment options and advice.  That's how you fight Wall Street.

If you check out the ASRS Twitter page, you will see that it is more professional and informative than PSPRS'.  I did not find a link to Mr. Wood's opinion piece on the ASRS page, though there were links relevant to millennials about financial resolutions, job interviews, and student debt.  Even though this was a discussion about Mr. Wood's piece, this is ultimately about PSPRS.  PSPRS continually boasts about its "successful" investment strategy, a strategy that is heavily dependent on multitudes of outside investment managers.  Yet they link to a cynical opinion piece that is meant to incite readers' anger against the same Wall Street firms that have earned millions off pensions like PSPRS.  To what end?  So that someone just out of college can remind all of us rubes how lucky we are to have PSPRS protecting us from Wall Street's predations? How they are protecting us from investments like the Fidelity Spartan 500 Index Fund (FUSEX), which has an annualized return of 9.93% over the last 28 years and an expense ratio of only 0.1% or the Fidelity Spartan Bond Index Fund (FBIDX), which has an annualized return of 6.24% over the past 26 years and an expense ratio of only 0.22%?

PSPRS' Twitter page is practically bereft of any useful information to PSPRS members or the public and the few tweets available are mostly inane or self-serving.  A professional and informative Twitter page befits a professional and member-focused organization like ASRS.  PSPRS' Twitter page is inane, cynical, and self-serving.  Readers can reach their own conclusions about what kind of organization PSPRS is.