FSRA's webinar to learn more about the new examination program for pension plan administrators

0:05

Hello, everyone, and welcome to today's webinar, Revamped Pension Plans Examination Program.

0:14

And before we get started, I'd like to go over a few items that you know how to participate in this event.

0:20

You have the opportunity to submit questions to today's presenters by typing them into the questions section of the GoToWebinar control panel.

0:29

You can send your questions in at any time during the presentation.

0:32

we will collect them and address them during the Q&A portion at the end of each of today's presentations. And with that, I would like to introduce Paul Martiniello from FSRA.

0:46

Welcome, Paul. Thank you, Carina. Good morning, everyone.

0:53

Thank you for attending our webinar on our revamp pension plans examination program for single and multi-employer pension plans.

1:02

As mentioned, My name is Paul Martiniello and I am the Director of Prudential Supervision of Single and Multi-ployer Pension Plans here at FISRA and I'm joined today by my colleagues, Vanessa Taylor, who is our Senior Pensions Engagement Consultant and Marco Siavada, who is our Senior Manager Relationship Management of Pensions and together we will be your host for today's webinar.

1:21

So following the successful pilot of a revamped approach this past year to conducting pension plan examinations, we formally launched the new approach this past month and today we wanted to take some time to provide you with an overview and a better understanding of the new program.

1:37

Before we go there, it is important to acknowledge the land we live and work on.

1:41

Next slide, please.

1:43

The land we're on is the traditional territory of many nations, including the Mississaugas of the Credit, the Anishinaabeg, the Chippewa, the Haudenosaunee, and the Wendat peoples, and is now home to many diverse First Nations, Inuit and Métis peoples.

1:57

Additionally, we acknowledge that Toronto is covered by Treaty 13 with the Mississaugas of the Credit and with the Williams Treaty signed with multiple Mississaugas and Chippewa bands.

2:07

Now let's turn to our agenda for today's webinar.

2:10

Next slide, please.

2:13

In a minute, I will turn it over to Marco and Vanessa who together will walk you through, first of all, a background on FSRA, who we are and the supervisor approach we have been utilizing since the inception of FSRA in 2019.

2:26

We'll go through some key changes to the plan examination approach and we will then take a deeper dive into the examination process itself.

2:35

And finally, we will conclude with a Q&A session, and as mentioned, your questions can be typed in.

2:40

We will group similar questions if applicable.

2:43

And I think most importantly, any questions we cannot take today as well as the recording of today's webinar and the slide deck will be posted to our website by the end of the month.

2:52

I hope you find today's webinar informative, and I will now turn things over to Marco and Vanessa.

2:59

Next slide, please.

3:05

Thank you, Paul, and good morning, everyone.

3:08

We're very excited to share with you an overview of our event examination program and to provide you with some insights into the overall process and a sense for what can be expected in a FISRA examination.

3:25

This webinar is a first for FISRA's pensions team.

3:29

And as Paul mentioned, we recognize that for some of you, this may be your first interaction with FISRA.

3:36

So with that, I'll provide you with a bit of a background before we delve into the examination process.

3:44

FISRA regulates a number of different financial services sectors, but our specific objects in the pension sector are to promote good administration of pension plans and to protect and safeguard the benefits and rights of beneficiaries.

4:00

Beyond that, FISRA is a principles-based regulator, which means in a broad sense that our activities are guided by what we identify as certain key underlying principles.

4:12

And with that said, FISRA has developed certain guiding principles with which we approach our work in the pension sector.

4:20

And they are firstly that we are risk-based, ensuring careful analysis and focus in terms the nature and size and complexity and potential impact of risks, that we are reasonable implementing actions and responses that are proportionate to the risks identified, that we are aware of the complexities within the sector, the roles of the stakeholders, as well as the unique characteristics of plans, that we are adaptable, recognizing that one size doesn't fit all in terms of regulatory approaches, that we are facilitative in terms of aiming to educate and to enable the sector to achieve the outcomes we think are important, that we are efficient and effective in that we continually assess the effectiveness of our guidance and tools, and that we are collaborative and transparent in terms of being committed to an ongoing dialogue with the sector.

5:25

For example, in having interactions like this webinar, where we can share details of new processes and initiatives that would be of interest to the sector.

5:35

And you'll note that throughout the webinar, the changes and revisions made to the examination program were really driven by these principles.

5:45

Next, the new framework builds on FISRA's risk base and outcomes focused supervisory approach to protect pension benefits and ensure good administration of plans.

6:01

It is a departure from the previous program which focused primarily on compliance and minimum standards of the Pension Benefits Act.

6:10

Key changes to the program include firstly, an alignment with FISRA's principles-based regulatory approach with increased emphasis on industry accepted guidelines which are largely driven from the Canadian Association of Pension Supervisory Authorities or CAPSA.

6:29

So there is emphasis on observation of those guidelines while still ensuring minimum compliance requirements from that.

6:39

The central and most notable change to the program is a greater emphasis on a risk-based approach with the primary focus of the examination being on five key risk areas.

6:54

So the first being with the sponsor and we'll conduct a review of the plan sponsor to better understand the nature of their business, their industry and the potential risks that the sponsor may face.

7:09

So this key risk area is really about obtaining a better sense for the challenges that could potentially impact the sponsor's ability to meet pension obligations.

7:24

Funding risk is a look at the plan's funding framework, and that includes a review of how the plan's funding objectives integrate with the plan's statement of investment policy procedures.

7:36

As well, we'll review the plan's risk appetite such that we have a better understanding that that risks are being effectively managed.

7:46

On the investment side, we are looking to obtain an understanding of the plan's approach to investments and that the approach is aligned with their fiduciary responsibility.

7:57

For administration, we'll conduct a review of the oversight of management and operations of the pension plan and its fund.

8:05

And that will include a review of complaints and inquiries, a look at records retention, we'll look at required filings and expenses, items of that nature.

8:19

And finally, governance really overlays all of the other areas as an overall view of the plan and how it is run.

8:27

We will review plan governance structure and that includes identified roles and responsibilities, performance monitoring, risk management, as well as oversight of compliance.

8:42

We've implemented a more dynamic and risk-based plan selection process and that's conducted on a quarterly basis.

8:51

The selection considers both a macro view of the risks and challenges in the pension sector and includes some industry scanning, proactive research of financial data points.

9:03

And that's balanced with a micro look at an inbound intelligence received by FISRA through routine filings and transactions.

9:15

Lastly, the program is conducted in a hybrid format to include remote functionality.

9:23

We recognize the evolution of remote work arrangements for many organizations.

9:29

And with that, we're equipped to better meet the needs of our stakeholders who operate in a remote environment while maintaining the ability to conduct examinations on site of the plan's premise where appropriate.

9:44

Next.

9:49

So here we have a high level overview of the process.

9:52

It does begin with plan selection.

9:55

It moves on to a kickoff with the selected plan, followed by a preliminary examination activity that acts as an initial risk assessment for us and it really provides direction for the examination and what areas we may need to focus on further and that activity will be further detailed in the coming slides.

10:21

We'll have a deeper dime of the information that's been provided and have conversations throughout so that the plan administrator is kept apprised of findings and examination progress.

10:34

We'll then report back the results of the examination to the planned administrator and discuss any follow-up or monitoring to follow-up.

10:44

The process is applicable to any single or multi-employer pension plan.

10:50

As far as length of time to conduct an examination, based on our experience in piloting the program over the past year, The length of time ranged from between four to eight weeks, and that includes transitional time in collecting and receiving supporting documentation, time for us to review and analyze the documentation, and for feedback loops within that time where we engage with the administrator periodically throughout.

11:24

And the frequency with which we engage with the administrator is really proportionate to the amount of information we receive to review the size and complexity of the plan.

11:35

So with that, we do try to provide some flexibility within the process as we recognize that there are times there are conflicting priorities or other work pressures for the administrator.

11:49

We expect that the program and process will continue to evolve so it is scalable and that we can adapt to changing practices or additional requirements as needed.

12:02

And now to provide a little more color to the process, my colleague, Vanessa, will now provide a little more detail to each step in the coming slides.

12:11

Next.

12:19

Great, thanks, Marco.

12:22

Now, beginning with the first step, as we alluded to earlier, the new selection process is risk-based and dynamic.

12:29

and by dynamic, we mean that there's adaptability and fluidity to the process, and it's now conducted quarterly.

12:37

We feel that conducting the selection process quarterly provides us with a good degree of agility and adapting our selection to the most appropriate and timely risk-based criteria available.

12:50

The selection process considers multiple criteria, including environmental scanning and inbound operational intelligence, as well as the proactive sectoral analysis driven by the five risk drivers we spoke to earlier.

13:07

We have a limited view of these risks.

13:09

So when there's publicly available information, we will analyze what we can, as well as look to internal data that we have through submissions of filings and transactions to identify plans for examination.

13:22

Assessing governance and how the plan is managed is challenging to do through a selection process and needs to be done through engagements like the examination itself.

13:32

So we rely on data points to select plans and look to the examination itself to complete our assessment of the plan.

13:40

Next, to kick off the examination, a member of our team will reach out to advise the plan may have been selected for an examination and provide an overview of the process, including next steps, as well as some insight as to why the plan was selected.

14:00

This question is something we get often, and it may assist the plan in preparing documentation for review.

14:07

As part of the preparation for the exam, plan administrators will be asked to complete a preliminary examination self-assessment to help direct the examination.

14:18

Our team will provide an overview of the document and answer any questions the administrator may have at the kickoff.

14:25

Following the call, the administrator will receive a formal start letter that details what was communicated during the call, and that letter effectively marks the start of the examination.

14:37

Next, the preliminary examination tool is a self-assessment to be completed by the plan administrator.

14:48

This exercise is intended to give our team members a general sense for the administration and overall governance of the plan in terms of what documents and practices are in place.

14:59

But most importantly, it provides us with a preliminary risk assessment that helps us set out resources required for the examination.

15:10

As noted in the FISRA guiding principles, we recognize that pension plans vary in size in nature and one size does not fit all.

15:20

And so this approach factors in proportionality and allows us the ability to be flexible in identifying the resources necessary to complete the examination at an early stage.

15:31

For example, we may learn from the onset of the completion of this tool that the plan is extremely well run based on documentation provided and discussion with the plan administrator. That results in a very low preliminary risk assessment.

15:46

And so that may shorten the amount of time we need to dedicate to this examination, which could be closed out in a more efficient manner.

15:54

This also provides administrators the opportunity to collect information that will be subject for review during the examination.

16:02

Administrators will complete the self-assessment to the best of their knowledge and include supporting documentation where appropriate.

16:09

And we ask that it be completed within two to three weeks from receipt of the start letter.

16:16

Next, the tool itself is an Excel-based spreadsheet and this slide shows a snapshot of what it looks like.

16:28

The first tab provides an introduction and some instruction on how to fill out the tool and prepare for the examination.

16:35

There is a plan information tab that we will pre-populate with what we have available.

16:41

And we will ask you to verify or fill in any gaps for that tab.

16:46

This is to ensure we have the most up-to-date information.

16:50

The other tabs then go through four main categories of governance, investment, funding and administration, which form the structure of the examination.

17:00

Within each tab, there are dropdowns to complete responses.

17:04

Where yes is selected, we would like to see supporting documentation to support the selection.

17:10

There is a tab at the end in purple which references requested documents, which we would like to see as part of the examination.

17:19

And lastly, there is a spot at the bottom for further notes and comments.

17:23

We have found that the more detail that's provided, the more fulsome the report back is, so we encourage you to provide as much detail as possible.

17:31

and certainly we encourage the plan administrator to reach out to us if they have any questions while completing it. Next.

17:44

Once the preliminary review is concluded this sets the tone for the main examination which is a deeper dive into the processes and practices of the plan structured around five key risk drivers as our guide as well as the results from the preliminary examination tool.

18:00

There is a two-way engagement throughout the examination which is predominantly in this phase.

18:05

Findings will be discussed as they are identified.

18:08

There's a continuous flow of communications, of communications, right?

18:12

So no surprises at the closing of the examination.

18:16

Next, as the exam concludes, our team will reach out to schedule a closing meeting with the plan administrators and fiduciaries to walk through our final observations and recommendations.

18:32

The administrator will receive a draft copy of the closing letter in advance of the meeting, and our team will walk through the letter with them.

18:39

This is an opportunity for the administrator to seek clarity on findings and ensure a clear understanding of FISRA's recommendations.

18:48

The administrator is welcome to invite any representative that they feel is important to the discussion and may have a greater level of expertise for the given topic.

18:57

Following the call, FISRA will finalize the draft letter and make adjustments where appropriate based on the conversation with the administrator.

19:06

Next, each section will include an observation based on our review of the documentation provided, as well as verbal interactions with plan representatives.

19:20

We will provide recommendations where we deem appropriate, as well as positive feedback on those areas and practices that we encourage the plan to continue.

19:31

A key feature to the letter is the introduction of a summary of examination findings in the appendix, which will clearly set out those observations and recommendations that are compliance related and those recommendations that are related to leading practices.

19:47

Compliance recommendations are really those that are tied directly to the requirements of the law, whereas recommended leading practices refer to those industry accepted guidelines or practices that we feel the plan would benefit from and the fiduciaries overall obligations under the PBA.

20:06

This appendix will be referred to by our team for any follow-up calls or conversations and acts as a good reference point for the administrator to follow.

20:16

Next, within 60 days of the date of this letter, we request a response from the administrator with an action plan and timeline to address the areas of risk and non-compliance summarized in the follow-ups can range from a phone call to another full examination.

20:39

This will be driven proportionately by the findings themselves as well as the degree of risk within them.

20:46

And now that concludes the overall process. I'll hand it over to Paul to close out the presentation.

21:01

Thank you, Vanessa and Marco. So a few questions have been coming in throughout the presentation.

21:09

I just want to remind everybody to please ask away.

21:15

You are encouraged to type your question in and we'll address them now.

21:23

And also as mentioned, we will be, if we don't get to certain questions today, we're happy to address them following this webinar.

21:33

I'll just, there's a couple of pretty straightforward ones that have been provided to us or have been asked of us, excuse me, the first one is, how would a plan advisor slash consultant be involved in a pension plan examination?

21:53

So- We expect that, you know, the administrator would really quarter back the examination from their end.

22:01

So we see the administrator as inviting who they would need to have at any discussion with our examination team and by our experience through what we've piloted over the past year.

22:17

Administrators have done a really good job of bringing who they needed to at a call to effectively respond to any questions and report that discussion. Great, thank you, Marko.

22:33

There was another question, actually there's a material and it will be posted as mentioned earlier in the presentation as well as a recording of this website and I think most importantly and just try to repeat this theme as much as possible we just encourage you all to connect with us anytime you can reach out to us directly and personally we're going to provide our direct contact information in the final slide actually maybe, Karina, if you can move to that slide now so people can have it, that'd be great.

23:08

Thank you.

23:11

There's a question around specifically on the preliminary examination tool, if that will be made available as an administrator.

23:22

Yes, absolutely.

23:23

We're happy to make that template available.

23:25

Again, reach out to us directly if you want to have a firsthand view what that looks like and I assume the question was asked to to be able to prepare for any potential examinations on behalf of either yourself as administrator or I believe this may be asking so long before your client. Just bear with me here.

24:02

What is the source of FISRA's leading practices.

24:08

So I would, I would just go back to what Marco alluded to earlier, we do rely on, on the CAPSA guidelines as a standard of leading practices.

24:26

And quite frankly, I would suggest with our own experience over time.

24:31

And that's one thing that I do to mention that we do plan at some point to produce some kind of aggregated report or summary to the sector that will show some trends and some of the leading practices we do see once we've gathered enough information.

24:56

I don't believe that's something that's ever done in the we think that's an important activity from as a regulator and it fits very well with our mandate and our approach to hopefully have that use as a tool in the future for plant administrators and their consultants and advisors. So thank you for that question.

25:20

There's a question on how many plans will be selected quarterly. I'll turn that over to either you Marco or Vanessa.

25:30

That's a good question, it depends.

25:32

So the selection process we have as Vanessa alluded to is pretty dynamic and we tend to land on various members.

25:44

Typically we end up with a range of 15 to 20 plans but with it being dynamic in the sense that we might change this criteria, that number could fluctuate a little bit.

26:03

That's it. I'll just add that that is, as pointed out, a key change to the procedure as opposed to being driven by a specific number of examinations to be conducted on an annual basis.

26:18

We've, we've pivoted to this more dynamic approach so the numbers will vary. I do expect we'll be publishing those numbers again and the broader aggregated view once we have enough data.

26:32

So, thank you for that question and next question, how will FISR be focusing on DB Plans first or a general mix of DC and DB Plan examinations and when will they start?

26:52

They've already begun and it is a mix of DB and DC Plans, really any single or multi-employer plan.

27:02

But we have we have already kicked off the new examination program over the past month so we're well underway.

27:10

Yeah, and just to add, we've done standalone DCs, just DB and combined DB and DC.

27:19

So we've done it all and we're doing it all going forward.

27:24

Great. I think that's an important point. Thank you, Vanessa.

27:27

it's our pilot we very we made sure we covered a combination of that just described by Vanessa so thank you for that question.

27:40

What is the operational intelligence you use to select plans for examination?

27:49

Well it's a little bit of both and I think I alluded to earlier it's a bit of a macro in proactively researching and having environmental scans.

28:01

But specific to operational, it's really about the inbound intelligence that we collect in terms of transactions and required filings.

28:12

That's predominantly what we view operationally.

28:20

Great, thank you for that question.

28:30

So, one question that came in on, will there be, are there penalties for observations not actioned?

28:41

And I think the straightforward answer to that would be, it would depend on what's not actioned, and it will fall into, or overall, for applying administrative monetary penalties.

28:58

Another question, thank you for that question.

29:02

Are all the plans going to be evaluated?

29:07

And I think the response there I would just suggest goes back to what's already been discussed in terms of specifically our dynamic selection process that it really is risk-based.

29:23

And so I can tell you we have many more plans and we can possibly cover off in a short time period.

29:33

So it will be driven by that.

29:37

So thank you for that question.

29:40

And then a question on will FISRA publish a report with findings from time to time to give plan sponsors an idea of the drink.

29:49

So yes, thank you for that question.

29:52

As I've already mentioned, that's absolutely a goal of ours.

29:55

It's not something I believe has been done in the past.

29:59

And much like the work we're doing in other sectors and other initiatives, we absolutely feel very strongly about the need to publish a report exactly as you suggest here that points out strengths, weaknesses, I'd say some trends as well.

30:15

Ideally, over time, we're going to be able to get to some trends and all in the name of facilitating education for the sector.

30:28

Thanks again for that question.

30:39

That, I believe, covers all of the questions we've received, so I will just give it another minute to see if anybody has any further questions.

31:04

Okay, another one just came in. I think it's a great question, so thank you for that.

31:07

Could the same plan be evaluated more than once? Vanessa, Marco?

31:15

The answer is potentially yes.

31:18

It will depend on what is picked up through the selection process and we do have a follow-up process as well.

31:28

I think Vanessa had alluded to that in the presentation.

31:33

So it's likely we'll reach out again just to reconnect with the administrator post-examination, but it is possible for a pension plan to be examined again down the road.

31:51

Great, thank you.

31:53

And we have another question, so thank you for that, regarding the confidentiality of documents being requested and the secure delivery method in terms of exchanging those or providing those to FISRA and asking if we can confirm what the protocol is in order to facilitate that.

32:19

Yep, documentation that we received is kept confidential to the examination and we utilize a system called Kiteworks which is a confidential document transfer system and so we work with the administrator typically at the beginning of the examination to walk through KiteWorks, its functionality and our documentation gets transferred through that.

32:50

Great, thank you.

32:55

Okay.

32:59

So that is the extent of the questions we have received.

33:05

Just give it another few seconds.

33:07

And while we're doing that, I just want to reiterate that we're happy to receive any follow-up questions, discussions you may want to have, if you want to reach out to us directly.

33:23

There is a question, sorry, one last one that came in here.

33:27

How much information will FISRA derive or take from the earlier benchmarking exercise and either the plan selection process or request for information?

33:35

So I suspect a little context on this question in with reference to benchmarking exercise, it's regarding multi-employer pension plans specifically.

33:46

So just to clarify for all the attendees here, FISRA has, in the past three years, been conducting a benchmarking exercise that followed the publication of eight leading practices, specifically for DB maps, although you could argue there's some, there are practices that could be applied to all kinds of pension plans.

34:08

However, we then went through a benchmarking exercise where H-PLAN benchmarked themselves against those linear practices and so we've basically been in communication with every MEP in Ontario and as a result they have not been part of the pilot for the examination process and I will also note that for those who are not aware that there is a target benefit framework that the Ministry of Finance has been consulting on and is currently in the process of producing regulations for this new framework that will become permanent as of January 2025.

34:51

For ourselves as FISDRA, we are currently looking at and developing supervisory guidance against these new regulations.

35:02

So all I can say is that the, for now that it's in process, but the examination process will become part of that supervisory approach.

35:13

And we will most certainly take the information that we've gained over the last years on the benchmark exercise when we consider plans for selection.

35:22

So thank you for that question.

35:26

Another question has come in.

35:28

Will you have additional trainings slash webinars for PAs in the future?

35:33

and I am assuming that stands for public administrators.

35:37

We don't currently plan on having an additional webinar, but we do plan on, in addition to posting this and the slide deck, we do plan on producing some documentation, certain topics that we feel that might require a bit more clarification.

35:56

So we'll look to continually enhance what's available on our website as a guide for administrators.

36:05

And as I've already mentioned, I just want to reiterate, we just can't encourage you enough to reach out to us at any point in time, if you have any questions or concerns on a basis, happy to entertain the call.

36:20

So thank you for that question, Karen.

36:39

All right, doesn't look like we have any other questions coming in.

36:50

So with that, I just want to again thank everybody for attending and look forward to hearing from anybody who wants to speak about this further and and interacting with you in the future so wish you all a very good day, and we will be speaking again soon.

37:13

Thank you.

1. What authority does FSRA have to request information through an examination, and how will this information be protected?

FSRA’s authority to make inquiries and conduct an examination falls under subsection 106(4) of the Pensions Benefits Act. FSRA uses a secure, file transfer system called Kiteworks to ensure information shared and collected is protected. Information collected over the course of an examination is intended for the purposes of examination and is not shared.

2. Is there any reference material available that will help administrators prepare for an examination and how can it be accessed?

Helpful examination information can be found on FSRA’s Pension Plan Examinations landing page, which includes links to the Examination Webinar and the Preliminary Examination Tool. Additionally, plan administrators^[1] are encouraged to visit FSRA’s Pensions page for helpful industry resources, including guidance on the Pension Plan Administrator Roles and Responsibilities, and to visit the Canadian Association of Pension Supervisory Authority (CAPSA) website for further sector resources. Throughout the course of a pension plan examination, FSRA will refer to industry accepted guidelines developed by CAPSA, as well as FSRA's own guidelines and supervisory approaches (i.e. MEPP Leading Practices).

3. Is the Pension Plan Examinations program applicable to all types of Pension Plans?

The Pension Plan Examinations program has been developed for Defined Benefit and Defined Contribution Single and Multi-Employer pension plans (SEPPs and MEPPS respectively). Jointly Sponsored Pension Plans (JSPPs) and Large Public Sector Pension Plans (LPSPPs) are subject to review by FSRA’s Prudential Supervision LPSPP team.

4. Will all Pension Plans be examined and how are there selected?

While it is possible for all plans to be examined, FSRA uses a dynamic and risk-based selection process that is conducted on a quarterly basis. The selection process considers a macro view of the risks within the pensions sector that includes industry scanning of economic and sectoral challenges. This is balanced with a micro view of plan-specific risk analysis including plan funding, plan investments, and history of compliance with regulatory requirements such as timely filing and remittances. The number of examinations performed per year is subject to those plans identified through risk-based plan selection, the degree of potential harm to member benefits, as well as capacity to conduct examinations. Ultimately, plans are selected based on an assessment of risk of multiple data points and could result in a plan being examined more than once.

5. Who should be involved in a Pension Plan examination?

FSRA will reach out to the plan administrator as the point of contact on record and will communicate with the administrator throughout the examination process. The plan administrator has the discretion to include any key personnel involved in plan operations and oversight, as well as any third-party service providers (Actuary, Investment Consultant, Custodian, etc.) to participate in calls.

6. How long does a Pension Plan examination take to complete?

Based on FSRA’s experience to date, the length of time ranges from 4-8 weeks. This includes transitional time in collecting and receiving supporting documentation, review and analysis, and feedback loops in which FSRA re-engages with the administrator periodically throughout the examination. Any follow-up to the examination, once completed, will fall outside of this range and will be addressed proportionately to the recommendations made.

7. What are the key differences between the previous Pension Plan Examination program and the new one?

8. How do you determine if the examination will be conducted remote vs on-site?

Examinations will be conducted remotely where it is feasible and efficient to do so. FSRA will apply a risk-based approach to determining whether an on-site examination is appropriate. FSRA will consider requests for an on-site examination should that be a preference for the administrator, for example in cases where documentation is only available in paper form.

9. Is there flexibility on timing for when the examination is conducted?

Generally, FSRA will work together with the plan administrator to accommodate scheduling conflicts. Where there are extenuating circumstances, FSRA has the flexibility to find a more suitable time to conduct the examination.

10. Is there a penalty for not having documentation available?

No. FSRA will apply a principles and risk-based approach to circumstances where documentation is not available and proceed to continue with the examination. With respect to required filings under the PBA, these are compliance requirements and would be subject to review and potential regulatory action.

11. Will the results of the examination by shared publicly?

Examination results are not shared publicly, as plan specific recommendations are confidential. However, FSRA intends on publishing an annual sector-wide, aggregated report that highlights general trends and observations made. This report will present opportunities for improvement for the purpose of transparent information sharing and education to the sector.

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^[1] An administrator must be a person, body or entity specified by the Pension Benefits Act (PBA). For most plans, the administrator is also the same entity as the employer of plan members and the plan sponsor. Another common form of administrator is a board of trustees.