A fter five years, experience with letters of credit should be reviewed by the regulator. The pools of capital held by Canada’s pension funds are critical to the security of the population’s retirement income. For example, large plans pay far lower fees on their investments than small ones...” (p.183, 9.3). Adding a new section 47.6 (after the new 47.5 recommended in section 2.1) to PBA Regulation 909 would accomplish this – suggested wording is shown below: 47.6 The employers who are required to make contributions under a public sector jointly-sponsored pension plan and the members of the pension plan are exempt from the requirement to make contributions under clause 4(2)(a) with respect to any solvency deficiency under the plan and from the requirement to make special payments under clauses 4(2)(c) and 4(2.4)(b) with respect to any solvency deficiency under the plan. Follow OPB's company page on LinkedIn, Open in new window ; Subscribe to OPB's channel on YouTube, Open in new window ; 1-800-668-6203; Contact us; Contactez-nous If you don’t, you'll have to wait until December 29 to get through to someone to help due to the bank holidays. OMERS Administration Corporation was also recently recognized as one of the top contenders for the 2009 National Awards in Governance by The Conference Board of Canada. Consideration should be given to applying the CANSIM interest rate to the combined pension. The Commission’s report also recommends the establishment of a Pension Community Advisory Council (PCAC). This recommendation requires further consultation to fully understand the proposed process and to ensure that it is necessary in view of the recommendations related to the expanded role of the pension regulator (Chapter 7 of the Commission’s report). OMERS recommends that the Pension Benefits Act be reviewed and amended as required, to permit multi-plan systems such as OMERS to administer multiple plans on a per member basis, rather than on a per-plan basis. All decisions and orders of the Superintendent should be subject to appeal to the Tribunal. We are pleased to see that the Commission (Expert Commission Recommendation 4-11) has endorsed OMERS recommendation regarding solvency funding exemption for JSPPs. OMERS welcomes the opportunity to respond to the report of the Ontario Expert Commission on Pensions (the Commission), led by Harry Arthurs. For example, the Pension Investment Association of Canada (PIAC) submission recommended that the government, “Exempt all public sector plans from solvency funding requirements due to their low probability of default.” Similarly, the Association of Canadian Pension Management (ACPM) submission and the Association of Municipalities of Ontario (AMO) submission both supported solvency exemption for public sector jointly-sponsored pension plans. Budget 4 It should be noted that the description of the 5, 15 and 25% Rules on page 85 of the Expert Commission’s report is incorrect. Arthurs goes on to say, “…lower investment fees are but one of the many advantages enjoyed by large plans over smaller ones and over individual savers. As with MEPPs, the JSPP plan administrator does not have an employment relationship with its members, and thus must rely on its participating employers to enrol members, collect and remit contributions and to provide such other information as is necessary for the administration of the plan. By signing in, I agree and confirm that I will only use eAccess and the information provided in it for the purpose of administration of the OMERS Pension Plans. In our submission to the Commission in October, 2007, OMERS recommended: Ontario, May 10, 2007. Old Age Pension Dates 2016. In our submission to the Commission, we noted that OMERS experience supports the Commission’s notion of encouraging the consolidation of smaller pension plans, either with compatible large partners, or by pooling their resources with similar-sized funds. We assume that the Expert Advisors are referencing this section with a view to adding the recommended timelines for responses by the Superintendent. The recommendation changes the term “former member” to “retired member.” Former member is a term used in the, Access to “all plan information” is a broad statement, which needs to be defined. The time for moving ahead is now.” OMERS agrees that delay must be avoided – immediate action is needed to strengthen and protect the viability of Ontario’s pension system. The basis for such legislation and regulations should be the Specified Ontario multi-employer pension plan regulation of 2007. The recommended approach for redrafting is to employ principles, wherever possible, supported by detailed rules where necessary. Whatever balance is struck, it should be one that facilitates a guiding principle of this report: that of open, fair, effective and adaptable regulation.”. 2 Exempt public sector jointly-sponsored pension plans from the Solvency Funding Requirement – by immediately amending the PBA regulations. The Pension Benefits Act should be reviewed and amended as required to permit sponsors of Ontario-registered pension plans to make the plan amendments required to permit employers and members to take advantage of appropriate models of phased-in retirement. Section 26(1) states that written notice should be provided to pension plan members who may be adversely affected by the registration of an amendment to the pension plan. OMERS fully supports the need to maintain the momentum in pension reform triggered by the Commission’s report. Also, the plan should not be required to store both paper and electronic copies, i.e., the electronic copy replaces the paper copy. OMERS would like to be involved in the consultation and discussion of the requirements. As a Multi-employer Pension Plan (MEPP), the OMERS Plan was created in 1962, in part through the merger of a number of existing municipal pension plans in Ontario. However, the current timeframes are also acceptable. It may be very challenging to obtain consensus on issues where stakeholder opinions are diametrically opposed. Section 22(4) deals with Administration: Conflict of Interest. If in fact the comments are meant to cover s. 21 of the PBA (reciprocal transfer agreement), this will impact the existing reciprocal transfer agreements. A legislated exemption would alleviate the potential unnecessary burden of additional contributions, caused by a solvency deficiency, on OMERS stakeholders and ultimately, taxpayers. In all cases the wording should be consistent – it should specify “x” days after the date that the plan administrator receives the completed notice of the event. These additional contributions often serve to increase a plan surplus once markets rebound or interest rates rise. Our commentary in this document refers only to recommendations contained in the report of the Expert Commission on Pensions. It will provide you with regular monthly payments when you retire as an OMERS Plan member. We look forward to working with the Ontario government as it considers and addresses the report’s findings and recommendations, and we are ready to assist with this important initiative. With the OMERS defined benefit pension plan you can confidently retire knowing that you will have income for life. The government should move quickly to put in place the Pension Champion and the Ontario Pension Regulator. In its report, the Commission indicates that it is in favour of removing the Quantitative Investment Restrictions on pension fund investing, with the following two recommendations addressing this issue: The Ontario government should endeavour to persuade the federal government to reform the federal investment rules and, in particular, to remove or amend particular quantitative restrictions that no longer make sense, such as those involving prohibitions on Canadian, but not foreign, investments. That (i) the Financial Services Commission Act and the Pension Benefits Act be amended to provide for rule-making authority for FSCO on pension matters, enhance the jurisdiction of the Tribunal with respect to pension matters, and provide it with an appropriate exclusivity to protect its jurisdiction; and (ii) the pension office within FSCO be provided with appropriate resources by supplementing the current industry levies with additional powers to charge pension funds an appropriate and fair fee for the services that the regulator is providing.”. We also believe that the additional requirements introduced in Recommendation 8.8 regarding the 30% Rule recommendation are unnecessary, as there are already safeguards in place under the PBA as we have indicated under OMERS Proposed Actions. Your pension is paid on the second last banking day of every month, except in December. Finally, large plans are more likely to survive than smaller ones, if only because the enterprises (or groups of enterprises) that sponsor them are likely to be more stable or resilient than those that sponsor small plans. The value of benefits provided by an “importing” plan should be deemed to be “comparable” to those provided by an “exporting” plan for purposes of the default option, if (a) approved by the Superintendent as approximating the aggregate collective value of such benefits, notwithstanding differences in the nature, value or terms of individual benefits, or (b) agreed to by a union representing active plan members affected by the transfer. We have not conducted a full review of the Pension Benefits Act (PBA)and regulations. Economy Here are the affected payment dates with the revised schedule. Recommendation: Housekeeping recommendations which clarify existing wording. Bill 133, as it currently reads, proposes amendments to both the PBA and the Family Law Act (FLA) which are in line with OMERS submission recommendations.This is a positive first step. In our submission to the Commission in October, 2007, OMERS recommended: That the Pension Benefits Act be amended to consist of the fundamental principles applicable to all pension plans in Ontario, such as the fiduciary duties and obligations of plan administrators, a ‘prudent person’ test for investment of pension funds, a broad purpose clause, the powers of the regulator, wind-up provisions, offence provisions and adequate minimum standards for plan design (eligibility for membership, vesting and locking in, portability and transfer options, and member communication).”. As survivors of deceased pensioners do not always notify the plan administrator, it would be useful and more cost efficient if pension plans could have access to the provincial death registry. Employers and plan members are represented equally on the boards of both corporations. 1 Exempting Public Sector Jointly-Sponsored Pension Plans from the Quantitative Restrictions on Pension Fund Investing, 2 Exempting Public Sector Jointly-Sponsored Pension Plans from the Solvency Funding Requirement, 3 Enhancing the Regulatory Relationship by Moving to a More Consultative Model and Providing the Regulator with Additional Tools and Resources, 4 Amending the Pension Benefits Act to Consist of the Fundamental Principles Applicable to all Pension Plans in Ontario. OMERS pension income provides peace of mind. Recommendation: This appears to conflict with the principles-based approach, as it could introduce excess rules. A move to a 12-year amortization period would impact the funding requirements of large plans – it could increase OMERS deficit funding requirement by approximately 15% to 20% in times of a going concern deficit. The theory behind these rules is that employers and members should decide jointly the level of funding appropriate in light of plan liabilities and other relevant factors, and the consequences if such funding proves insufficient to fund accrued benefits in the event of a wind-up. These address a number of technical issues, as well as the Expert Advisors’ Consensus Recommendations. However, the Expert Commission's recommendations do not go far enough4. The recommendation should clearly reference group transfers under 80(5) and 81(5) of the. Our commentary in this document refers only to recommendations contained in the report of the Expert Commission on Pensions. Revisions to the Pension Benefits Act should be drafted to provide both rules-based and principles-based approaches, as appropriate. Pension Payment Dates 2020 Payroll Month Pay Date January January 24 February February 24 March March 24 April April 24 May May 22 June June 24 July July 24 August August 24 September September 24 October October 23 November November 24 December December 18. Page 129 of the report, which speaks about rules and principles in pension regulation, reads, “…the precise balance struck between rules and principles will heavily influence the optimal design, powers and staffing requirements of the pension regulator. A jointly-sponsored pension plan (JSPP) with a long tradition of strong employer/member governance; A large multi-employer defined benefit plan with a highly diversified membership of more than 900 employers and 390,000 members; and. The day that you're paid usually depends on when you applied for the benefit. 1 David Dodge, Governor of the Bank of Canada, in remarks to Conference Board of Canada’s 2007 Pension Summit: Striking the Right Balance, Toronto, Recommendation: Section 48 deals with Pre-retirement Death Benefits: Beneficiary Entitlement on Death. 3 Ontario Teachers’ Pension Plan, OMERS, Hospitals of Ontario Pension Plan, Ontario Pension Board, OPSEU Pension Trust, Ontario Power Generation Pension Plan, Colleges of Applied Arts and Technology Pension Plan, Hydro One Pension Plan, TTC Pension Plan, and Toronto, Queens and York universities pension plans. Issue: VíSTCOR . OMERS welcomes the opportunity to work with the government on this important initiative. This is because there are three bank holidays to take into account during the festive season, which fall on December 25, December 28 and January 1. The scheduling of a pension summit should not cause the government to delay making changes to the pension landscape. As the Commission pointed out, the present regulatory impediments to group transfers are inappropriate and should be changed. The DWP has confirmed the below payment dates for state pension recipients to The Sun. Now more than ever, Canadians are looking for leadership to pave the way for their financial security in retirement. Your payments are made on the last working day of each month except your December payment which is paid earlier due to Christmas. News Corp is a network of leading companies in the worlds of diversified media, news, education, and information services. This access is currently denied to virtually all pension plans. In December, the payment is made on the second last banking day before December 25. Immediate action is needed. The Commission acknowledges that drafting new legislation is likely to take a long time, especially if it is to be done well, and that extensive consultation will be necessary when creating a new structure to alter the dynamics of Ontario’s pension system. Issue: The Commission’s report represents a positive, and long awaited, first step in the crucial task of reforming the current pension system in Ontario. Overview: Our comments in Appendix C refer only to the issues contained in the report titled Expert Advisors’ Consensus Recommendations on Technical and Operational Issues. OMERS supports this recommendation. This section states that an administrator (or member of an administrative committee/board) shall not knowingly permit a conflict of interest. It recommends that steps be taken to encourage cooperation among existing smaller plans. Regulation 24 specifies that the interest rate applied for Defined Benefit (DB) payments is the Canadian Socio-Economic Information Management System (CANSIM) series V122515 compiled by Statistics Canada, and available on the website maintained by the Bank of Canada, over a reasonably recent period such that the averaging period does not exceed twelve months. During a breakfast session on November 21, 2008, hosted by the Commission, Harry Arthurs mentioned that there may be an opportunity for one of the large pension plans, for example OMERS or the Ontario Teachers’ Pension Plan, to take a role in the ongoing administration and investment management of the OPA. As indicated in our submission, this would decrease the administrative burden and cost for administrators (and by extension other plan members) while at the same time increasing predictability for members and their families. and beneficiaries of the OMERS pension plans. For example, to fund a $1 billion deficit, annual special payments would have to increase from approximately $105 million under the 15-year amortization to $120 million under the 12-year amortization. We have not commented on the following Expert Panel recommendations: Section 8 deals with Registration and Administration: Administrator. Section 113 deals with Time for Actions by Administrator. October 28, 2020; November 26, 2020; December 22, 2020 ; 2021. Issue: This includes recommendations that strengthen the power of the pension regulator and create a new Pension Tribunal of Ontario. The regulator should urge the governing bodies of professions whose members are involved in the pension field to: OMERS agrees in principle with the recommendation. In addition, PBA changes should also allow retroactivity for members who are active as at the effective date of a transfer agreement. In its report, the Commission cites the OMERS Pension Plan as a useful model when combining MEPPs. OMERS Pension Estimate . By applying the 30 to 90 bps of potential returns to the $250 billion in assets under management for the 12 largest Ontario-only registered pension plans3, it is possible to infer that the Quantitative Investment Restrictions deny Ontario workers potential pension investment returns of $700 million to $2 billion a year. While there were no direct recommendations related to our submission, we are pleased that the Commission has recognized the need to facilitate innovation in plan design. We have not conducted a full review of the Pension Benefits Act (PBA) and regulations to identify additional issues. The government should promptly address the pension arrangements for groups of public service employees affected by past divestments and transfers, whether by allowing these groups to use the group asset transfer process proposed in Recommendation 5-4, or by other means, including negotiations with their representatives. The Expert Advisors identified a number of very important technical recommendations, such as providing pension plans with access to the provincial government death registry, to enhance the efficiency of plan administration. We have included additional specific responses and comments in our three appendices. CPP Pension Dates 2016. The Ontario government should not wait for the federal government; it should move immediately to remove the Quantitative Investment Restrictions and rely on the existing prudential standards. Ontario.ca If you have chosen your own payment date or frequency, the nominated pension payment date (also known as Next Payment Date) is the date we initiate your pension payment. Canada Pension Pay Dates … Recommendation: Retirees will get up to £230 extra a year in their state pension from April next year, the government has confirmed. Once again, any new model considered should fully embrace the benefits of consolidation. The time frames for providing statements, the period for the election and the period for payment should be consistent with other pension regulators across the country. In their 2001 submissions, the Association of Canadian Pension Management (ACPM), representing 400 pension plans; the Pension Investment Association of Canada (PIAC), whose member funds are responsible for the oversight and management of over $910 billion in assets (based on 2007 data); the Canadian Life and Health Insurance Association, whose members administered about two-thirds of Canada’s pension plans; and the Investment Counsel Association of Canada, with 64 member firms managing institutional and individual client assets – all stated their preference to be regulated by prudential obligations rather than mathematics or formulas. As the OMERS Pension Plans are subject to joint governance, plan participants are already aware that benefits could be reduced in the event of a plan wind-up, and there is therefore no requirement for additional protection. Receiving advance notice from the employer of cessation of employment is not a common practice, especially with terminations. The current composition of the AC and SC boards includes a retired plan member, as specified in the OMERS Act, 2006. However, interest is not paid. Pension policy and legislation ought to facilitate the growth and operation of large-scale pension plans or to enable and encourage cooperation among small- and medium-sized plans. The Supplemental Plan introduced for police, firefighters and paramedics was exempted in 2007. Pension cheques are mailed to arrive at the beginning of the month. Except in emergencies, the process of regulation-making should provide for timely notice to and comment by stakeholders and other interested parties, and for advice by the proposed Pension Community Advisory Council. For example, an expanded CPP could leverage from the existing administration and investment management activities that CPP already has in place. We assume that the Expert Advisors are referencing this section with a view to adding the responsibilities of the employer in addition to those of the administrator. Phone: 1.800.774.5070 (toll free in NS) or 902.424.5070. In our submission to the Commission in October, 2007, OMERS recommended: Also, election forms must indicate the benefit amount (where applicable) – the administrator requires final financial information in order to provide accurate figures and this would not normally be available in advance of termination of employment. This service is provided on News Group Newspapers' Limited's Standard Terms and Conditions in accordance with our Privacy & Cookie Policy. The concept of an adverse amendment can then be removed from the Act. The new Ontario Pension Regulator should have power to make rules in order to define and lend greater specificity and clarity to its governing statute and regulations. Section 27 concerns the provision of written annual statements for plan members. The requirement that “the value of the benefits provided in the ‘importing’ plan should be deemed to be ‘comparable’ to those provided by the ‘exporting’ plan” is an unnecessary restriction which will negatively impact portability. For those who reached the state pension age before April 6, 2016, you’ll be getting the old state pension, known as the basic state pension. The money you set aside from every paycheque is matched by your employer, and we carefully invest it in high-quality assets, diversified around the world, to meet the pension promise of a secure retirement. Date Event; 1: Indexing for the year 2020 is 2.0%. In our submission to the Commission in October, 2007, OMERS recommended: For pension purposes, the time period of the strike is not included on your pension record. OMERS supports the concept of a central agency that would act as a data warehouse and provide a tracking function for information on stranded pensions. For change to be successful, the Ontario Pension Regulator must involve the regulated bodies in the development of principles and their interpretation. Section 29 refers to the requirement to make pension plan documentation available for inspection, without charge, by members, former members, relatives and their agents. Governments have been increasingly interested in principles-based legislation, such as that recently adopted by the U.K. Pension Regulator, as an alternative to the traditional approach to regulation whereby a myriad of detailed rules are designed to prescribe regulated behaviour. A large pension fund investor pursuing a global investment mandate. Appendix C – Expert Advisors’ Consensus Recommendations on Technical and Operational Issues. These consultations should focus on rules governing the conduct of professionals in pension practice, and on the redesign of regulatory and governance structures and processes – in both cases, with a view to ensuring the honest and transparent administration of pension plans. The timing of payments should be taken into consideration when determining the point from which late interest is to be paid (some plans pay at the end of the month and some pay in advance at the beginning of the month). We also highlighted that other pension funds could benefit from having funds like OMERS, with its investment expertise, assume responsibility for investing their pension assets. Many of these plans, I believe, would welcome such an opportunity, as they are reaching a point of maturity past which their future net cash flows will shrink, and their ability to undertake new investments will be severely reduced. If the plan administrator incurs costs as a result, in the end, the entire plan membership pays. This size advantage is compounded along almost every vector of plan success. The quantitative restrictions (the “Quantitative Investment Restrictions”) in Schedule III of the Federal Investment Regulations: The Canadian pension industry has repeatedly asked that Quantitative Investment Restrictions be replaced by the “prudent person” principle. Your HOOPP pension is normally paid on the first day of each month. The legislation should clarify rights and remedies in the event a participating employer does not fulfill its responsibilities and a more expedited regulatory enforcement process should be adopted. Wait 10 working days from the payment date to contact us. It is so significant, in fact, that plan size may be a greater determinant of a member’s pension than plan design.” (p.184), In proposing a new strategy for Ontario’s occupational pensions system, the Commission’s report suggests, “…the government would have to allow Ontario’s existing large plans to amend their membership criteria and mandates…a fairly simple procedure should be established to make it possible for them to broaden the scope of their activities and the qualifications for plan membership, if they wish to do so. By signing in, I agree that I have read and agree with the OMERS Confidentiality and Access Agreement on the e-access registration form. This gives members the flexibility to consolidate their pension service under the new plan or choose one of the other options provided. The Quantitative Investment Restrictions are cumbersome to comply with, difficult to interpret and are not reflective of the market exposure of the funds. The Expert Advisors identified a number of very important recommendations, such as providing pension plans with access to the provincial government death registry, to enhance the efficiency of plan administration. Issue: Your employer will report this time to OMERS as a … It is also supported by other Canadian jurisdictions. 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