Ontario's Bill 236 Pension Reforms Revised by Standing Committee

Following several days of public hearings and receipt of many written submissions, on April 19, 2010 the Standing Committee on Finance and Economic Affairs reported on Ontario Bill 236, Pension Benefits Amendment Act, 2010, making a number of amendments to the Bill.

Probably the most significant change in the revised version of the Bill, which was ordered for third reading, was the extension of the modified surplus sharing regime to partial wind-ups.

The current surplus sharing regime requires employers to satisfy member consent thresholds AND demonstrate surplus ownership. Bill 236 (similar to the federal regime) originally permitted employers to withdraw surplus from their pension plans on full wind-up without needing to prove surplus ownership if member consent thresholds were satisfied and other prescribed requirements were satisfied. Future and pending partial wind-up surplus withdrawals (prior to the elimination of partial wind-ups in 2012) were, however, being treated differently under Bill 236 and remained subject to troublesome conflicts in the current legislation which have caused problems for employers and affected members for years. Revised Bill 236 fixes the problem by prescribing identical treatment for full and partial wind-up surplus distributions. This means that once the Bill becomes law, plan sponsors with pending partial wind-ups (and pending partial wind-up surplus distributions) will be able to take advantage of this modified surplus sharing regime and withdraw surplus by proving ownership or with the required level of member consent.

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Court Orders Rectification of Plan Text - Allowing Plan Sponsor Relief from Unexpected Liability

A recent decision of the Ontario Superior Court of Justice has confirmed that, in the right circumstances, a plan sponsor can remedy incorrect pension plan language by utilizing the equitable remedy of rectification.

In MTD Products Limited v. Baldin, the employer had decided to provide an unreduced early retirement benefit for one long-time employee – James Dobbie. The plan language provided that on early retirement, member benefits were to be reduced by 1/2 of 1% for each full month that the pension was paid prior to the “normal retirement date”. In order to accommodate Mr. Dobbie’s unreduced retirement benefit, it was necessary to amend the plan text.

The consulting firm engaged to draft the amendment suggested amending the plan to provide unreduced early retirement benefits for all members of the plan, and not just Mr. Dobbie. Due to cost considerations, the employer rejected this suggestion and understood that the plan was amended to provide early retirement to Mr. Dobbie only. (This understanding was consistent with the consultant’s instructions and internal notes).

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Are You Ready for the First Wave of U.S. Health Care Reform?

U.S. health care reform comes into effect years from now, right? Well, not quite. A number of important provisions will be coming into effect soon, generally on January 1, 2011 for non-union calendar year plans. U.S. plan sponsors need to know about them even if their plans are insured. In fact, in addition to making sure that certain family members are eligible for coverage under the new rules, companies with retiree coverage (particularly retiree drug coverage) need to make decisions now.

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Federal Government Introduces Pension Reform Amendments

With the introduction of Bill C-9 – this year’s budget bill – on March 29th, the federal government is beginning to move forward on a number of the pension reforms that it had announced last fall.

For instance, Bill C-9 contains the increase to the Income Tax Act pension surplus threshold from 10% to 25% of actuarial liabilities (as discussed in our March 25, 2010 post). Bill C-9 also includes a number of significant amendments to the federal Pension Benefits Standards Act (the PBSA), although many of these will require amendments to the Pension Benefits Standards Regulations (PBSR) before they can be fully implemented.

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