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Pension Plan Governance Policies: Have You Reviewed Yours Lately?

When was the last time you thought about pension plan governance? Or reviewed your pension governance policies? It would be great if your answer is “recently”. However, if you’re like many organizations whose answer is “I can’t remember” or “a while ago”, then you need to be aware of the potential risks of not regularly reviewing your pension plan governance structure.

Pension governance is often referred to as the decision-making structure and supporting policies and processes for overseeing, managing and administering a pension plan to ensure that fiduciary and other obligations of the plan are met.

Under pension standards legislation, the plan administrator is ultimately responsible for the governance of the pension plan. Plan administrators have a statutory fiduciary obligation to ensure that the plan is administered in accordance with the best interests of the plan members. Using “best efforts” is not sufficient. Fostering good governance practices, including having a written pension governance policy, will help you discharge this obligation. Without them, the likelihood of breaching your fiduciary standard of care increases. This could lead to claims and litigation against the pension plan and those responsible for plan administration, and even offences under pension standards legislation. It was only a few years ago that the trustees of a large multi-employer pension plan, who were responsible for plan administration, were charged and convicted under the Ontario Pension Benefits Act for breaching their fiduciary duty with respect to the plan’s investments, and fined a record-setting amount.

As a result, if you already have a written pension governance policy in place, now is a good time to review it. Conducting periodic reviews will assist you in making sure any required changes to that policy are made, and that your governance framework as a whole continues to be relevant and adequate to discharge your fiduciary duty. This in turn will ensure that there is proper oversight of the plan’s day-to-day operations, plan member interests are protected, and the risk of member complaints and claims against the pension plan are reduced.

If you don’t already have a written pension governance policy in place, now is the time to create one! A written pension governance policy can be an effective tool for improving your pension governance system. It’s also something that most regulators will ask for when conducting an examination of your pension plan.

As a starting point, any person involved in pension governance should be familiar with the guidelines published by the Canadian Association of Pension Supervisory Authorities (CAPSA) and in particular, Guideline No. 4. Originally released in 2004, CAPSA is currently updating Guideline No. 4, which sets out guiding principles and established best practices for pension plan governance. CAPSA has also developed several other guidelines that will assist plan administrators in developing good governance policies such as Guideline No. 3 on Capital Accumulation Plans, Guideline No. 5 on Fund Holder Arrangements, Guideline No. 6 on Pension Plan Prudent Investment Practices, and Guideline No. 8 on Defined Contribution Pension Plans. For a link to all of CAPSA’s guidelines, click here.

Although the CAPSA guidelines are not legally binding, pension regulators and most (if not all) pension practitioners expect plan administrators to follow them as industry standard. For that reason, establishing a written pension governance policy that takes into account the principles from the guidelines, after consultation with legal counsel, is recommended.

So if you haven’t reviewed your pension governance structure lately, or you don’t have a pension governance policy, now is the time to take action. Doing so will help ensure your plan is administered in accordance with applicable legislation (including your fiduciary obligation), and help avoid potential claims and deficiencies in the event of pension plan examinations.

Pension Plan Governance Policies: Have You Reviewed Yours Lately?

CPP Expansion

Retirement savings in this country has been a hot topic of late, and yesterday evening in Vancouver the federal government and (most of) the provinces announced that they have reached a deal to expand the Canada Pension Plan. The deal must be approved by July 15 of this year.

The proposed changes will roll out over seven years, beginning in 2019, and mean both a bigger benefit to retirees and bigger monthly contributions by employers and employees.

Under the current CPP, employers and employees each contribute 4.95% of income between $3,500 and $54,900. The proposed plan would see that annual pensionable income increase up to $82,700 by 2025. For example, contributions for a typical worker earning about $55,000 would initially increase by $7 a month in 2019, eventually increasing to $34 a month in 2025. Employers would match those contributions.

The current CPP replaces 25% of earnings up to $54,900, with a maximum CPP benefit of $13,110. The average annual payment is $7,974.84. The expanded CPP would aim to replace one third of income up to the new $82,700 ceiling. The maximum annual payout would increase by about one third to $17,478.

CPP reform requires the approval of the federal government and seven of the provinces containing two thirds of Canada’s population. All of the provinces except Manitoba and Quebec have signed on to the agreement announced yesterday. Quebec Finance Minister Carlos Leitao said he supported the agreement but that Quebec would be proposing an alternate version of the expansion in Quebec.

What about the ORPP?

Ontario’s Finance Minister, Charles Sousa, has announced that this new deal will signal the end of his government’s proposed Ontario Retirement Pension Plan.

What does this mean for you?

These changes raise many important issues for unionized and non-union employers across Canada. We will be providing further insights as things develop and more details become available. In the meantime, if you have any questions about what an expanded CPP means for you, please contact us.

CPP Expansion

Why HR Professionals Should Demand A Benefit Communications Policy

If your job description includes responsibility for communicating pensions and benefits to fellow employees, then you must already know that with each new communication comes increased potential legal liability for your organization. However, unlike the production of a defective widget, where each new sale increases potential liability by one, each defective benefit communication increases potential liability by a multiple equal to the number of recipient beneficiaries.  Hence, years of benefit miscommunication has an overwhelming impact on an organization’s potential legal liability.

Canadian courts and arbitrators have shown an increasing propensity to award damages, or provide restitution, to employees where it can be shown that employer communications are untrue, inaccurate, misleading, ambiguous or omit important details otherwise relevant to those being asked to make important (often irrevocable) decisions related to health, welfare or retirement.

Benefit miscommunications can cost your organization in other ways too. Numerous court decisions in Canada demonstrate time and again how employer cost-savings programs, based on reducing post-retirement benefits, can be derailed by ambiguous communications about the employer’s right to change those benefits following retirement from employment.

While eliminating all benefit communications might appear to be a logical means of reducing potential legal liability, there are many sound business and legal reasons for regular communications to employees about their benefits. Your employer’s pension and benefit programs are expensive and were implemented, in part, to attract and retain valuable employees. If you don’t tell employees about your excellent programs, why bother having them in the first place?  In some cases you have no choice and must issue benefits-related communications.  For example, the law imposes on pension plan administrators an obligation to provide on-going and ad hoc communications to plan members about their entitlements.

The challenge for employers, therefore, is how best to effectively communicate the excellent pension and benefit programs available to employees while minimizing potential legal liability and ensuring that proposed future changes to those programs won’t be hampered by the phantoms of past communications.

While there is no single step that will cure all past benefit miscommunications, the path to overcome the benefit communication challenge must first be paved with a comprehensive Benefit Communications Policy (BCP) based, in part, on past court decisions which highlight the legal hurdles to be surmounted.

An effective BCP must ensure that future benefit communications that may be relied upon by employees to make important decisions:

  • are thoroughly vetted so as to eliminate any untrue, inaccurate or misleading statements (or omissions);
  • are clearly written and devoid of ambiguous or vague terminology;
  • do not predict future events, unless thoroughly qualified;
  • do not project future investment outcomes, unless thoroughly qualified; and
  • where appropriate, include customized language, unique to each organization, reserving to the employer the right to make future changes to its benefit programs, even following retirement.

A BCP should become an integral part of your organization’s risk management strategy and should align with existing procedures and human resource capabilities. Of course, your BCP will not be worth the paper it’s written on if there is no C-suite buy-in. A Board of Directors stamp-of-approval may, therefore, be essential to the success of your policy and a single executive should be made accountable for the BCP to ensure that necessary resources are allocated to its implementation and adherence.

While a well-designed, successfully implemented and strictly enforced BCP will not cure past benefit miscommunications, it should significantly decrease the risk of future legal claims against your organization and increase the likelihood that upcoming cost-saving measures, which include changes to pension and benefit programs, will not be derailed by ambiguous employee communications.

Why HR Professionals Should Demand A Benefit Communications Policy

A Quick Guide to the Taxation of Retiring Allowances

When an employee’s employment is terminated without cause, the employee will typically receive some form of a termination/severance payment. All or part of this termination/severance payment may be considered a “retiring allowance” under the Income Tax Act, providing the employee with additional options in respect of the allocation of the payment.

Whether a payment qualifies as a “retiring allowance” will depend on the reason for the payment. Under the Income Tax Act, a retiring allowance is an amount paid to an employee on or after the date his or her employment terminates for the purpose of recognizing long service, or for the loss of employment. As a result of the definition of “retiring allowance”, a payment made pursuant to the applicable employment standards legislation may or may not qualify as a retiring allowance, depending on the circumstances.

Employees with service prior to 1996 may be able to take advantage of preferential tax treatment by transferring part of their retiring allowance to a registered retirement savings plan (RRSP) or registered pension plan (RPP) regardless of their “contribution room”, up to certain limits.

The portion that can be transferred directly to a RRSP or RPP regardless of the contribution room is commonly referred to as the ‘eligible portion’ of the retiring allowance.

Here is how to calculate the eligible portion of a retiring allowance:

  • $2,000 for each year or part of a year of service before 1996 that the employee or former employee worked for the employer (or a person related to the employer); plus
  • $1,500 for each year or part of a year of service prior to 1989 of that employment in which none of the employer’s contributions to a RPP or deferred profit sharing plan were vested in the employee’s name when the employer paid the retiring allowance.

Eligible portion of a retiring allowance:

The eligible portion of a retiring allowance must be transferred directly into the employee’s RRSP or RPP on a tax-free basis. It is not determined by, nor does it affect, the employee’s regular RRSP contribution room. The direct transfer of the retiring allowance to an RPP may result in a pension adjustment (PA) that will affect the employee’s RRSP deduction limit in subsequent years. Note that an employee cannot transfer any part of an eligible retiring allowance directly to a spousal or common-law partner RRSP.

Ineligible portion of a retiring allowance:

The non-eligible portion of a retiring allowance (i.e. amounts over and above the eligible portion) may also be transferred directly into the employee’s RRSP, or a spousal or common-law partner’s RRSP, if the employee has the available RRSP contribution room. If the transfer is made directly to the RRSP, tax need not be withheld.

Things to keep in mind:

  • Contributions to an employee’s RRSP can only be made until the end of the year in which he or she turns age 71.
  • Employers contributing remuneration directly to an employee’s RRSP on his or her behalf should have reasonable grounds to believe that the employee has sufficient RRSP contribution room and can deduct the contribution for the year.

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A Quick Guide to the Taxation of Retiring Allowances

Ontario Retirement Pension Plan: a guide

Media coverage about the Ontario Retirement Pension Plan (ORPP) has been unrelenting for the past two years. The Ontario government has made many announcements setting out its vision for its new, government-run defined benefit pension plan for Ontario employees which will be similar to the Canada Pension Plan (CPP).

Are you finding it hard to keep track? Here is an up-to-date guide. More details are in the articles listed at the end of this guide.

When is the ORPP coming into effect?

The Ontario government recently changed the effective dates. It’s likely that the following schedule is final.

Employers who had an active registered pension plan on August 11, 2015, are exempt until January 1, 2020. It doesn’t matter if their existing plan does not currently qualify as “comparable” under the ORPP rules. It doesn’t matter if their existing pension plan doesn’t apply to all of their employees. All of those lucky employers have until January 1, 2020 to decide how to react to the ORPP.

All other employers of Ontario workers will be required to start making contributions to the ORPP on the following dates, unless they adopt a “comparable” registered pension plan:

  • January 1, 2018 if more than 50 employees; and
  • January 1, 2019 if 50 or fewer employees.

What types of pension plans will qualify as “comparable”? 

The Ontario government has not budged from its position that group registered retirement savings plans do not qualify as “comparable”. It is now certain that Ontario employers who offer only a Group RRSP, deferred profit sharing plan or other type of non-pension savings plan, will have to either change their plans, or join the ORPP.

See the links at the end of this guide for details of what registered pension plans do qualify as “comparable.” Beware: this is not a simple, blanket exemption. Every registered pension plan will have to be closely examined to ensure that it perfectly complies with the details of what the Ontario government deems to be “comparable”. Does your registered pension plan have a waiting period for plan entry or service caps? Are there classes of employees who are not required to join your plan (e.g. certain fixed-term, contract, call-in or other classes of permitted excluded employees)? If the answer is yes, not all of your employees will be members of a “comparable” plan for ORPP purposes. Those employees will need to join the ORPP, while your other employees will not.

The ORPP Administration Corporation will soon start communicating with employers to confirm their enrolment date in the ORPP, and to verify which employers have “comparable” plans and are therefore exempt.

Is the ORPP now law?                        

Yes. In 2015 a very brief piece of legislation was adopted without many specifics. On April 14, 2016 the Ontario government released Bill 186, the Ontario Retirement Pension Plan Act (Strengthening Retirement Security for Ontarians), 2016. It is 50 pages of legislative details about the new regime. More details have been promised in regulations that will be released in the summer of 2016.

Will it go away if the Canada Pension Plan is enhanced?

Don’t count on it. Federal, provincial and territorial finance ministers will be meeting in June of 2016 to discuss possible changes to the CPP. It’s a long and uncertain political road to get to an enhanced CPP. It may never happen. Meanwhile, the Premier of Ontario has repeatedly said that the Ontario government is pressing ahead with the ORPP.

What’s new?                                    

The recent introduction of Bill 186 in the Ontario Legislature (on April 14, 2016), with all of its detailed rules about the ORPP, is exciting for lawyers. Details in the Bill include a regime for enforcement, guidelines for the collection of personal information, unsurprising points about the treatment of pensions earned under the ORPP on marriage breakdown, death, and so on. Many of these details are not new, so the Bill is less exciting for employers.

One interesting new detail in the Bill applies to directors of corporations. If they receive a “stipend or remuneration” for their service as a director, they will be subject to the ORPP unless an exemption applies.

Want more information?

Contact any member of the Dentons Canada pension group, or click on the following links:

 

 

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Ontario Retirement Pension Plan: a guide

Out with the Old, In with the New: What’s New with the Ontario Pension Regulator

FSCO reminds administrators about their roles and responsibilities

On January 25, 2016, the Financial Services Commission of Ontario (“FSCO”) issued a new policy that describes the roles and responsibilities of administrators of registered pension plans (policy A300-101). It replaces aging policies which were published in 1990 and 1992 (policies A300-100 and A300-150). Things have not changed drastically in the last two and a half decades. In fact, much of the new policy echoes the old. Some of the new elements in the policy refer to recent legislative and regulatory changes. In summary:

  • FSCO emphasizes the key responsibilities of pension plan administrators to comply with the federal investment regulations and the new requirements regarding environmental, social and governance factors with respect to the Statement of Investment Policies and Procedures.
  • Regulatory filings must be made electronically through the Pension Services Portal, including requests for an extension of a filing deadline.
  • As of January 1, 2015, administrators must provide statements of pension benefits to former members and retired members every two years.
  • The administrator is responsible for addressing inquiries and complaints from plan beneficiaries, or delegating the task to an agent if the administrator does not have the necessary knowledge.
  • FSCO emphasizes that the administrator must monitor and review delegated activities and that certain duties cannot be delegated. More information can be found in CAPSA Guideline No. 6.
  • The conflicts of interest section of the new policy has been expanded to reference CAPSA Guideline No. 4, while another section of the policy expounds on the “prudent person rule” as the fiduciary standard that applies to administrators.
  • Finally, the new policy sets out the need for prudent record-keeping practices, making reference to the relevant FSCO policy, and the administrator’s duty to make certain records available for inspection.

Ontario plan administrators will pay more to the regulator

On February 10, 2016, FSCO published its 2015-2016 preliminary pension assessment for the entire pension sector, and issued pension assessment invoices for all Ontario-registered pension plans. Primarily, these invoices set out the amount that must be paid for the year by each pension plan administrator to cover all estimated expenses and expenditures incurred by FSCO for the pension sector, along with a per member cost for their own plan.

This assessment is, however, simply an estimate of FSCO’s expenses and expenditures for this fiscal year. The actual cost will only be known by March of 2017. At that point, next year’s preliminary assessment will have been issued absorbing this year’s over or undervaluation of the actual cost of FSCO’s expenses.

The 2014-2015 total pension assessment for Ontario was approximately $15 million. The current (2015-2016) preliminary pension assessment is slightly higher.

New FSCO form for joint & survivor pension waiver

FSCO has issued a new Form 8 to be used by a former spouse to waive his/her right to a survivor benefit on the death of a retired member in the case of a marriage breakdown. It is essential that plan administrators use this new form.

Do not hesitate to contact any member of the Dentons Pension Group if you have any questions.

Out with the Old, In with the New: What’s New with the Ontario Pension Regulator

ORPP Update: Enrollment and Phase-in of Contributions Delayed

The Ontario and federal governments announced on February 16, 2016 that they have reached an agreement regarding the Ontario Retirement Pension Plan (ORPP) and improving pensions for Canadians.  With contributions originally set to begin next year, the Ontario government now proposes to phase-in the launch of the ORPP by starting enrollment in January 2017 and commencing collection of contributions in January 2018.

How will this affect businesses?

If applicable, the delay will give businesses more time to enroll in the ORPP, something that many organizations have been asking for.  Large employers who would have been required to start making contributions to the ORPP on January 1, 2017 will now have one additional year to prepare for the ORPP and consider whether changes should be made to their existing retirement and savings programs.

There was no mention of delaying enrollment or contributions for small and medium-sized employers in the Ontario government’s announcement. Based on the current enrollment schedule, small and medium-sized employers without a registered workplace pension plan will be required to contribute to the ORPP starting January 1, 2019 and January 1, 2018 respectively.

CPP enhancements and next steps

The delay will also provide more time for the federal government and other provinces to discuss and develop options for enhancing the Canada Pension Plan (CPP).  If provincial agreement on CPP enhancement is not reached, the Ontario government is committed to moving forward with the ORPP.  The federal government acknowledges this and has agreed to facilitate plan registration and data sharing agreements and help ensure that contributions are collected efficiently and cost-effectively.

To read the government bulletin on the announcement, click here.

ORPP Update: Enrollment and Phase-in of Contributions Delayed

ORPP: Additional Design Details Released

On January 26, 2016, additional design details of the Ontario Retirement Pension Plan (ORPP) were released by the Ontario government.  The government reconfirmed its commitment to implement the ORPP beginning January 1, 2017, ensuring that by 2020, every eligible employee in Ontario will be part of the ORPP or a comparable workplace pension plan.

The following is a summary of the additional design details.  Stay tuned for further postings which will put the details into context and discuss the implications for employers.

What employers should know: 

  • Contributions: ORPP contributions will be based on an employee’s pensionable earnings between $3,500 and $90,000, and will include cash and non-cash earnings and amounts beyond base salary such as bonuses and commissions.   
  • Definition of employment in Ontario: A person will be considered employed in Ontario for ORPP membership purposes if he or she:
    • is required to report to work at an establishment of the employer in Ontario, or
    • is not required to report to work at an employer’s Ontario establishment but is paid by the employing establishment in Ontario.
  • Comparability test:  Employers and employees in Ontario will be required to participate in the ORPP unless they participate in a comparable pension plan, subject to certain exceptions.  For information on the comparability tests, please see our August 12, 2015 posting.  The government has since released the following additional details relating to the comparability test:
    • Subset level: For pension plans with more than one group of employees (e.g. full- and part-time, union and non-union, etc.) and different benefit formulas for groups or “subsets” of employees, the comparability test will apply at the group or “subset” level.
    • Voluntary contributions: Voluntary contributions to a defined contribution pension plan will not be taken into account when determining if the plan is comparable to the ORPP.  Contributions to a defined contribution pension plan must be mandatory in order for them to be included in the comparability test.
    • Multi-Employer Pension Plans (MEPPs): The comparability test for a MEPP will be applied separately for each participating employer based on the employer’s collective bargaining agreements or employee agreements at the subset level, as defined by plan governing documents.  Employers will have the option to assess comparability using the defined benefit accrual or defined contribution rate threshold.
  • Waiting periods: Employees waiting to join their employer’s comparable pension plan will be required to participate in the ORPP during the waiting period.
  • Employer opt-in: Employers with a “comparable workplace pension plan” can opt-in to the ORPP on or after January 1, 2020.
  • Non-resident workers: Non-resident workers (for tax purposes) earning income over $3,500 that is subject to Canadian and Ontario income tax will be included in the ORPP.  However, if a non-resident worker is exempt from tax under an applicable tax treaty between Canada and another country, they will be exempt from participating in the ORPP.
  • Other workers: Individuals in receipt of ORPP benefits may opt-in to the ORPP if they return to eligible employment.  There will also be religious exemptions for certain workers, similar to the Canada Pension Plan (CPP).

ORPP benefits for employees:

  • Benefit formula: ORPP benefits will accrue at a rate of 0.375% of annual earnings per year and will be calculated using members’ average earnings over their career.  The ORPP is designed to provide a 15% income replacement rate to members who participate for over 40 years.
  • Payment of benefits: The ORPP will begin paying benefits starting in 2022.  Members will be eligible for retirement under the ORPP as early as age 60, and may postpone retirement until age 71.
  • Indexation: Benefits will be indexed according to average growth of wages and salaries as outlined by Statistics Canada pre-retirement, and indexed according to the Consumer Price Index post-retirement.
  • Pre-retirement survivor benefits: If a member dies before retirement, a lump sum based on the actuarial equivalent value of his/her pension will be paid to an eligible spouse, the member’s beneficiary or estate.
  • Post-retirement survivor benefits: If a member dies after retirement with an eligible spouse, the spouse will receive a survivor benefit equal to 60% of the member’s actuarially adjusted pension.  If the spouse waives his or her right to a survivor pension prior to the member’s retirement, or the member retires without an eligible spouse, the member would receive his or her full retirement pension with a 10-year guarantee period.  If the member dies within that guarantee period, the remaining value of his/her full retirement pension will be paid to his/her spouse, beneficiary or estate as an actuarially equivalent lump sum.

Other details:

  • Plan sustainability: A funding policy has been established for the ORPP to ensure that the plan is sustainable over the long-term.  In addition, the government will establish an Office of the Chief Actuary to conduct triennial valuations of the ORPP and to provide advice and analysis.
  • Plan review and changes: The ORPP will be reviewed five years after its full implementation and subsequent reviews will occur every ten years.  Fundamental changes to the ORPP that would substantially impact member benefits and are not resulting from funding policy adjustments would require the consent of at least 60% of ORPP members.

The Ontario government will set out these and other details about the ORPP in forthcoming legislation.

To read the Ontario government’s technical bulletin regarding these details, click here.  To read our previous ORPP postings, click the links below:

ORPP: Additional Design Details Released

ORPP: What’s next now that the election is over

With a new federal Liberal government coming into office on November 4, 2015, what does this mean for the Ontario Retirement Pension Plan (ORPP)?  That’s the question on the minds of many employers and workers in Ontario.

As part of its campaign platform, the federal Liberals promised to work with the provinces and territories, workers, employers, and retiree organizations to enhance the Canada Pension Plan (CPP).  Now that they’ve won a majority government, CPP expansion is back on the table.  This could mean higher employer and employee contributions and also higher CPP benefits for retirees.  As a result, it’s possible that the ORPP will be put on hold.  Ontario’s Premier Wynne has always stated that expanding the CPP was her first choice; the ORPP was a response to the federal Conservative party’s refusal to do so.

What can we expect in the coming months?

Justin Trudeau, the prime minister-designate, has committed to begin talks with the provinces on how to improve the CPP within three months of taking office, so it’s likely that a meeting of the federal and provincial finance ministers will be scheduled in the near future.  But don’t expect the CPP to be expanded any time soon.  Consent among at least 2/3rds of the provinces, having in the aggregate at least 2/3rds of the population of all of the provinces, is required before any changes can be made.  It could take years to obtain this level of agreement.

Prior to the election, Premier Wynne suggested that she would be willing to drop the idea of a provincial pension plan if the federal Liberals win.  However, she recently stated that until the federal Liberals make good on their pledge to enhance the CPP, she would continue with her plan for the ORPP.

For the time being, it seems that the Ontario government will stay on course to establish the ORPP by the 2017 deadline.  This will be an easier task now, as we can expect support from the federal government to help implement the plan.

What should employers do?

All Canadian employers should be aware of, and monitor, possible proposed changes to the CPP in order to assess the potential impacts to its organization.  In addition, employers with Ontario employees should continue to review and assess their retirement savings arrangements and determine whether changes should be made, keeping in mind that the ORPP is, for now, required to be in place by January 1, 2017.

For more information on the ORPP and how the proposed plan will work, click here to read our previous postings:

ORPP: What’s next now that the election is over

British Columbia: A guide to B.C.’s new pension legislation for HR professionals

On September 30, 2015, British Columbia’s new Pension Benefits Standards Act (PBSA) and Regulation came into effect.  The PBSA has wide-ranging implications for HR Professionals who oversee BC-registered pension plans and certain non-BC-registered pension plans with BC members. Among other things, all provincially regulated pension plans with BC members must be administered in a manner consistent with the PBSA effective September 30, 2015, including immediate vesting and locking-in for all service and new portability provisions for BC members. Compliance amendments to bring pension plans in-line with the PBSA must be filed with applicable regulators by December 31, 2015.  In addition, administrators of BC-registered pension plans must file a Contribution Schedule with the plan’s fund holder by the end of October, 2015, and prepare written Governance, Funding and Records Retention policies by the end of 2015.  The PBSA authorizes the Superintendent to impose administrative penalties on corporations and individuals for non-compliance and increases financial penalties, to a maximum of $500,000, for offences under the Act.  To read more about these and other requirements of the PBSA and Regulation, please follow this link: A Guide to BC’s new pension legislation for HR Professionals.

British Columbia: A guide to B.C.’s new pension legislation for HR professionals