An independent fiduciary and conflict of interest review of the New York State Common Retirement Fund (Fund), released today by New York State Comptroller Thomas P. DiNapoli, commended the Comptroller and Fund staff for holding “themselves to the highest ethical, professional and conflict of interest standards” and for being “well-prepared for the challenges that the [COVID-19] pandemic posed.” The review was conducted by Kroll LLC.
“The New York State Common Retirement Fund has proven once again to be a leader in transparency, ethics and performance,” DiNapoli said. “I’m proud of the outstanding work my staff has performed, especially under the difficult circumstances imposed by the pandemic. Amid very turbulent times for the markets, we will look to act on Kroll’s recommendations and ensure the Fund is well positioned for the years ahead to protect the pension benefits of our over 1.1 million members.”
Kroll reviewed documents for all investment transactions requiring DiNapoli’s approval during the review period of April 1, 2018, through March 31, 2021. Kroll concluded the transactions were approved and closed according to the Fund’s policies and legal requirements.
The analysis concluded that: “From the Comptroller down through the organization, Common Retirement Fund staff were knowledgeable, professional, and dedicated to their roles and we did not discover any unethical behavior or misconduct. The Common Retirement Fund was able to sustain operational integrity and meet their fiduciary duties despite the challenges presented by the pandemic. The Common Retirement Fund, under the leadership of the Comptroller, continues to be a leader amongst its peers for management and operational transparency.”
Kroll noted the great strides the Fund made in implementing past recommendations, particularly in staffing, but recommended adding staff and resources for compliance and information technology. In addition, Kroll recommended that the Fund establish a committee or working group to prepare for high-impact, unlikely events and develop policies and procedures to mitigate risks they might pose.
The independent review is mandated every three years as part of the regulatory framework established by the Department of Financial Services in partnership with the State Comptroller’s office in 2008. This is the fourth review completed since then.
Background on New York State Common Retirement Fund
The New York State Common Retirement Fund is one of the largest public pension funds in the United States with assets of approximately $279.7 billion as of Dec. 31, 2021. The Fund holds and invests the assets of the New York State and Local Retirement System on behalf of more than one million state and local government employees and retirees and their beneficiaries. It has consistently been ranked as one of the best managed and best funded plans in the nation.