Pensions consultation summary report | Financial Services Regulatory Authority of Ontario

Feedback from the sector:

During the consultation period of October 10 to November 16, 2023, FSRA received 4 submissions from stakeholders in the Pensions sector, each of which provided feedback on FSRA’s proposed Statement of Priorities for fiscal year 2024-25. The submissions and FSRA’s responses were available on FSRA’s website.

FSRA thanked all stakeholders that took the time to comment. FSRA carefully considered all feedback before finalizing and publishing the 2024-2027 Annual Business Plan.

Contributors to public consultation – Pensions sector:

The following stakeholders submitted comments on FSRA’s proposed SOP for fiscal 2024-25 for Pensions items:

Organization	Stakeholder representative
1. Consumer Advisory Panel (“CAP”)	N/A
2. CAAT Pension Plan (“CAAT”)	David Gordon
3. Canadian Life & Health Insurance Association (“CLHIA”)	Stephen Frank
4. Desjardins Group (“Desjardins”)	Giuseppina Marra

Education and awareness

Stakeholder	Summary of Feedback	FSRA’s Response
Consumer Advisory Panel	The CAP requested for definition for the 3 levels of funding for pension plans (i.e., going concern funding, solvency funding, and wind-up funding), and an explanation of the requirements of oversight of solvency funding for regulated pension plans.	FSRA thanked the stakeholder for its submission and will give this comment further consideration as Pensions focuses on member education through Pension Awareness Day.

Transparency and information

Stakeholder	Summary of Feedback	FSRA’s Response
Consumer Advisory Panel	Research suggested that a general lack of awareness existed about FSRA and what it can do to support plan members (consumers). FSRA must seize opportunities to ensure regulated entities include information about its mandate and services in the event consumers need to understand how to resolve a dispute. As an example, FSRA could require that information be incorporated in the annual information package that pension plan sponsors are currently required to distribute.	FSRA thanked the stakeholder for its submission and will give this comment further consideration as Pensions focuses on bringing information to plan members.

Stakeholder

Summary of Feedback

FSRA’s Response

Consumer Advisory Panel

Research suggested that a general lack of awareness existed about FSRA and what it can do to support plan members (consumers).

FSRA must seize opportunities to ensure regulated entities include information about its mandate and services in the event consumers need to understand how to resolve a dispute. As an example, FSRA could require that information be incorporated in the annual information package that pension plan sponsors are currently required to distribute.

FSRA thanked the stakeholder for its submission and will give this comment further consideration as Pensions focuses on bringing information to plan members.

Principles-based regulation

Stakeholder	Summary of Feedback	FSRA’s Response
CAAT	A stakeholder recommended that FSRA maintain a principles-based and not overly prescriptive approach when determining how to strengthen and implement their framework on supervising LPSPPs, to ensure that plans can continue innovating in the pension space and expanding pension access for more Ontarians.	FSRA thanked the stakeholder for its submission. FSRA is committed to a principles-based, outcomes-focused approach to regulation and supervision of the pension sector, including for LPSPPs.

Uniqueness of pension landscape

Stakeholder	Summary of Feedback	FSRA’s Response
CAAT	A stakeholder also highlighted the uniqueness of Plans like theirs, both from a governance and investment strategy perspective and recommended that FSRA should avoid a one-size-fits-all approach. Recommended that FSRA should consider differentiating between the pension sector and other sectors when discussing consumers and noted that there should be greater awareness over the fact that pension plans lacks consumers in the traditional sense.	FSRA thanked the stakeholder for its submission. As part of risk-based supervision, FSRA made considerable progress in developing Guidance and supervision tools that recognized the varying attributes of pension plans. FSRA will consider the stakeholder’s recommendation to better note the differences between consumers in the traditional sense and pension plan members in future Guidance.

Stakeholder

Summary of Feedback

FSRA’s Response

CAAT

A stakeholder also highlighted the uniqueness of Plans like theirs, both from a governance and investment strategy perspective and recommended that FSRA should avoid a one-size-fits-all approach.

Recommended that FSRA should consider differentiating between the pension sector and other sectors when discussing consumers and noted that there should be greater awareness over the fact that pension plans lacks consumers in the traditional sense.

FSRA thanked the stakeholder for its submission. As part of risk-based supervision, FSRA made considerable progress in developing Guidance and supervision tools that recognized the varying attributes of pension plans. FSRA will consider the stakeholder’s recommendation to better note the differences between consumers in the traditional sense and pension plan members in future Guidance.

Proposed pension priorities

Stakeholder	Summary of Feedback	FSRA’s Response
CLHIA	A stakeholder supported FSRA's focus on defined benefit pension plans and the development of a target benefit framework for multi-employer pension plans. It supported FSRA's review of the long-term viability of the pension benefit guarantee fund. The stakeholder encouraged FSRA to work with relevant Ontario Ministries to simplify the introduction of automatic features in pension plans. It also requested that FSRA prioritize the review of the federal Pooled Registered Pension Plans Act to include decumulation only PRPPs.	FSRA thanked the stakeholder for its submission. FSRA will continue to work with the Ministry of Finance and discuss priorities recommended.

Stakeholder

Summary of Feedback

FSRA’s Response

CLHIA

A stakeholder supported FSRA's focus on defined benefit pension plans and the development of a target benefit framework for multi-employer pension plans. It supported FSRA's review of the long-term viability of the pension benefit guarantee fund. The stakeholder encouraged FSRA to work with relevant Ontario Ministries to simplify the introduction of automatic features in pension plans. It also requested that FSRA prioritize the review of the federal Pooled Registered Pension Plans Act to include decumulation only PRPPs.

FSRA thanked the stakeholder for its submission.

FSRA will continue to work with the Ministry of Finance and discuss priorities recommended.

Implementation of target benefit framework

Stakeholder	Summary of Feedback	FSRA’s Response
Desjardins	Cross sector feedback contained brief mention of support for FSRA’s work and implementation of target benefit framework for MEPPs.	FSRA thanked the stakeholder for its submission and their support for the key deliverables included in the proposed 2024-2025 Statement of Priorities and Budget.