ID
2020-001

Type
Supervision
Sector
Pensions
Status
Public comment closed
Date
Comment Due Date

Thank you for providing your feedback on FSRA’s Proposed Supervisory Approach for Actively Monitored Single-Employer Defined Benefit plans.

We appreciate the comments and questions received to date. Your feedback helped to inform our final approach, which we have now posted.

Read: Approach No. PE0199APP: Supervisory Approach for Single Employer Defined Benefit Pension Plans that are Actively Monitored

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Sector Comment Date posted
Pensions
[2020-001] Simon Laxon - Willis Towers Watson
Please find enclosed our submission with respect to the Proposed Supervisory Approach for Single Employer Defined Benefit Pension Plans that are Actively Monitored.
Pensions
[2020-001] Brian Jenkins - ActuBen Consulting Inc.
My addition to the "Proposed Supervisory Approach for Single Employer Defined Benefit Pension Plans that are Actively Monitored" consultation is attached. FSRA appears to have no direct way to submit documents in any other way.
Health Service Providers
[2020-001] Charles D. Crawford - C. Crawford Medicine Professional Corp
For a small business like mine with a single person pension, the cost you are imposing with your assessment fee is outrageously high and unfair. My fee has more than doubled which is assuring that for the modest capital in my pension will not increase above the rate of inflation.
Pensions
[2020-001] Zar Rakovski
Please forward the attached letter to all persons associated.
Pensions
[2020-001] Brian Jenkins - ActuBen Consulting
I just wanted to comment on a piece of the "Proposed Supervisory Approach for Actively Monitored Single-Employer DB Plans". I think that the proposals are good for larger sized pension plans, but really miss the treatment of mid-size and smaller DB plans and in particular those plans considered as designated plans, whether by compensation or by status as a shareholder. Ontario has so far been uninvolved with the imposition by the federal government of an actuarial basis for funding that ensures deficiencies in the plans. Those plans that are not shareholder plans may well be a future drain on the PBGF due to the insufficient funding. For IPPs, the "IPP Minimum Benefit", under the current rules, guarantees that plans will go bankrupt by channelling surplus out of the Plan (including that which should be associated with active members) so that the Plan will generally not be able to sustain fluctuations in investment returns and mortality (*)-- with no "escape" route being permitted by Ontario except by expensive annuities. While the statements of intent are great for largers plans, I think FSRA needs to seriously look at the problems that imposing large plan rules on small plans that must deal with the special issues of small plans.
* in a 10 person plan with a q for each of .03 one would expect 0.3 deaths. It cannot happen. The built fluctuations of death or survival gains and losses have large impacts on the small plan which does not happen in a 10,000 life plan.
Date posted Sector Question and response
Pensions

Question: Why have my annual fees gone up 251% in 1 year.
This is outrageous for plan administration.
The standard fee is up 300% from $250 to $750

FSRA response:

FSRA’s Proposed Supervisory Approach for Single Employer Defined Benefit Pension Plans that are Actively Monitored only applies to single employer defined benefit plans where there where there may be a concern with respect to the security of the pension benefits promised.

This Approach will not apply to Individual Pension Plans and Designated Pension Plans. However, FSRA appreciates the input on the impact of our fees.  FSRA will take this input into consideration when we review the fee and assessment structure.

We would also like to note the Ontario Government initiated a consultation on a proposal to exempt certain individual pension plans and designated plans from the Pension Benefits Act. While the consultation is now closed, you can read more about this consultation on the government’s consultation page: https://www.ontario.ca/page/consultation-individual-pension-plans-and-designated-plans.