The Financial Services Regulatory Authority of Ontario (FSRA) and the Office of the Superintendent of Financial Institutions (OSFI) established the Technical Advisory Committee on Defined Contributions plans (the Committee). The Committee was established to review the approaches of both regulators to supervising Defined Contributions (DC) plans and where possible find opportunities for regulatory improvement and harmonization. Through this collaboration, FSRA and OSFI worked with the Committee towards improving outcomes for plan members. The Committee also focused on enhancing regulatory efficiency and effectiveness for DC plans.
The Committee met six times with the following outcomes and recommendations:
Pension and non-pension capital accumulation plans
- The Committee was of the view that DC pension plans are a better vehicle to deliver good retirement outcomes relative to other employment-based group savings plans (e.g. group RRSPs, DPSPs, TFSAs). However, the Committee identified that non-pension group savings plans are often favoured by plan sponsors for a variety of reasons. In terms of retirement outcomes, the Committee was of the view that DC plans provide advantages including “locking-in” rules and more robust administrator and regulatory oversight – but place additional filing and oversight responsibilities on sponsors and administrators. This is often seen as a drawback and a reason for offering a non-pension savings vehicle.
Improve regulatory guidance for DC plans
- The Committee identified a number of recommendations to improve outcomes of DC pension plans.
- The Committee proposed that these recommendations be presented to the Canadian Association of Pension Supervisory Authorities (CAPSA) to be considered in the review of the Guidelines for Capital Accumulation Plans (“CAP Guideline”) of the Joint Forum of Financial Market Regulators. In light of the wide acceptance of CAP Guidelines, the Committee recommended putting forward its recommendations to CAPSA as a way to reduce regulatory duplication and support harmonization across Canada. The recommendations are appended to this summary.
- Next steps include:
- CAPSA’s continued work on the CAP Guideline with publishing targeted for July 2022.
- Following this release, OSFI and FSRA will review the guidance and may reconvene the Committee to assess the merits of developing complementary guidance.
Promote member engagement
- A plain-language member-focused guide was developed with the Committee to support improved awareness and understanding of DC plans. The guide has been endorsed by CAPSA and is expected to be made available on CAPSA’s website. The guide will also be made available by OSFI and FSRA as well as by any industry participant or regulatory office that chooses to do so.
- The Committee strongly supported the need to provide retirement income projections to plan members. Such projections are considered an important tool to enable plan members to make well-informed financial and retirement planning decisions and to encourage members to augment their projected retirement income, if desired.
Explore regulatory efficiency and effectiveness
- The Committee identified ways to improve regulatory efficiency and effectiveness for DC plan administrators through simplified regulatory filings and reduced data collection. To that end, FSRA and OSFI are conducting a review of regulatory filings and data collected. The review considers input received from the Committee and is being balanced with the need to supervise the sector and ensure that plans continue to be well administered and that plan members continue to be protected.
- The Committee recommended that FSRA and OSFI continue to explore and consider opportunities to support DC plan administrators in providing decumulation options to their plan members within the existing regulatory and legislative framework.
- The Committee encouraged FSRA and OSFI to continue to evaluate other resources and tools (e.g. small business toolkit) to support administrators of small pension plans and employers who are considering sponsoring DC plans.
- Over the course of 2022, FSRA will review DC plan administration (and the use of life insurance companies and third-party service providers) to inform FSRA’s future supervision of DC plans including supervisory processes and tools.
- Similarly, OSFI will apply the insights gained through the Committee to further develop its Supervisory Framework for Federally Regulated Pension Plans.
- FSRA and OSFI intend to keep CAPSA informed of their work.