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Pensions & Benefits Law A Discussion of Canadian and U.S./Cross-Border Pension & Benefit Legal Issues

Category Archives: DB Plan Funding

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Expert Committee Pressing for Pension Reform in Quebec

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Pension Reform

Back in the fall of 2011, an expert committee chaired by Alban D’Amours was mandated by the Quebec government to analyze the state of the Quebec retirement income system and to make recommendations on how to improve it in light of the new economic and demographic realities. The Committee released a voluminous report on April… Continue Reading

Plan’s Funded Status Required to be Disclosed under Freedom of Information Request

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Plan Administration

Pension plan sponsors may be surprised to learn that information provided to pension regulators pursuant to statutory filing obligations could be more widely disclosed through an “access to information” request. In a recent decision, the B.C. Assistant Information and Privacy Commissioner ordered the B.C. Financial Institutions Commission (FICOM), which regulates B.C. registered pension plans, to… Continue Reading

Indalex: What Are the Pension Implications?

Posted in Bankruptcy, Canada Pensions & Benefits Law, DB Plan Funding

On February 1, 2013, the Supreme Court of Canada released its much anticipated decision in Sun Indalex Finance, LLC v. United Steelworkers, a case which pitted the claims of pensioners against those of secured creditors in the context of the insolvency of the employer plan sponsor. The Supreme Court’s decision in Indalex largely overturned the… Continue Reading

Re Northern Sawmills Inc. – Court Considers Post-Indalex Pension Claims in Receivership

Posted in Bankruptcy, Canada Pensions & Benefits Law, DB Plan Funding

This is another post-Indalex pension deficit priority case. Due to factual differences from Indalex, however, the pension claims were largely rejected. In the fall of 2008, Northern Sawmills Inc. idled its operations and laid off most of its employees. In January 2011, PricewaterhouseCoopers was appointed as Receiver over the assets of Northern Sawmills Inc., pursuant… Continue Reading

Ontario Pension Plans Will be Permitted to Use Letters of Credit

Posted in DB Plan Funding, Pension Reform

Effective January 1, 2013, certain Ontario employers will be able to use letters of credit to fund their pension plans’ solvency deficiencies. Provisions permitting letters of credit were added to the Ontario Pension Benefits Act (the PBA) in late 2010 when Bill 120 was passed, but they did not come into force pending the publication… Continue Reading

Alberta Introduces New Pension Legislation

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Innovation & Plan Design, Legislation & Regulations, Pension Reform

Almost four years after the Joint Expert Panel on Pension Standards (JEPPS) submitted its final report with recommendations to fundamentally reform Alberta and British Columbia’s pension systems, the Alberta government has introduced Bill 10, Employment Pension Plans Act. Similar to B.C.’s Bill 38, which was passed earlier this year, Bill 10, if passed, will replace… Continue Reading

Régie Des Rentes Releases Unfavourable Position on Margins for Adverse Deviations

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Plan Administration, Regulator Policies & Communications

Effective December 31, 2010, revisions were made by the Canadian Institute of Actuaries (CIA) to its Standards of Practice – Practice-Specific Standards for Pension Plans. In particular, the revised CIA Standards of Practice now provide that assumptions for going concern valuations are either best estimates or best estimates modified to incorporate margins for adverse deviations… Continue Reading

Alberta Extends Solvency Funding Relief

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Legislation & Regulations, Regulator Policies & Communications

Following up on the solvency funding relief for Alberta specified multi-employer pension plans (SMEPPs) which was passed last year, the Alberta government recently amended the Employment Pension Plans Regulation to also provide solvency funding relief to defined benefit plans which are not SMEPPs. Notably, the regulation does not require any form of member consent, or… Continue Reading

British Columbia Bill 38 Includes Some Novel Pension Reforms

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Innovation & Plan Design, Legislation & Regulations, Pension Reform

On April 30, 2012, British Columbia introduced Bill 38, Pension Benefits Standards Act, for first reading. If passed, the current British Columbia Pension Benefits Standards Act (PBSA) would be repealed and replaced in its entirety by Bill 38. Bill 38 marks the first significant amendments to British Columbia’s pension regime since the Joint Expert Panel… Continue Reading

Ontario Government Announces Consultation with Public Sector Plans

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Public Sector Plans

Following up on its 2012 budget, the Ontario government announced that it will begin consultations on a new legislative framework for jointly sponsored public sector pension plans (JSPPs). As the government indicated previously, their focus is to make public sector pension plans "more sustainable for members and more affordable for taxpayers.” In addition, the Ontario… Continue Reading

Pension Plan Restructuring (Part I)

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Plan Conversions, Plan Wind-Ups

These days, many plan sponsors are looking to exit the defined benefit (DB) world – largely for the following reasons:  they want to cut benefit funding and administration costs, as market volatility and low interest rates drive up solvency deficits and make planning more difficult; to achieve better planning and budgeting by making pension liabilities… Continue Reading

Ontario Budget: Implications for Private and Public Sector Pensions

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Innovation & Plan Design, Legislation & Regulations, Pension Reform, Plan Administration, Public Sector Plans

The Ontario government’s 2012 Budget, released yesterday, includes a number of announcements which will be of interest to administrators of both private and public sector pension plans. Some Good News for Private Sector Employers The government recognized that as a result of ongoing market volatility and low interest rates many private sector defined benefit plans… Continue Reading

Timminco Limited: CCAA Court Considers Fiduciary Obligations Post-Indalex

Posted in Bankruptcy, Canada Pensions & Benefits Law, DB Plan Funding

Timminco Limited is among the first reported cases to be released following the Ontario Court of Appeal’s April 7, 2011 decision in Re Indalex. There are two Timminco decisions – Timminco 1 and Timminco 2. Indalex Recap Recall, that in Indalex, contrary to widely accepted principles governing pensions under the Companies’ Creditors Arrangement Act (the… Continue Reading

OSFI Provides More Guidance re Letters of Credit

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Pension Reform, Regulator Policies & Communications

Over the past two years we have seen a number of amendments to federal pension legislation with respect to the funding of defined benefit (DB) plans (see April 1, 2010 and December 17, 2010 posts). These reforms include amendments permitting plan sponsors to use letters of credit in lieu of making solvency payments to a… Continue Reading

Quebec Announces Extension of Solvency Funding Relief for DB Plans

Posted in Bankruptcy, Canada Pensions & Benefits Law, DB Plan Funding, Pension Reform

Back in 2009, the Quebec government adopted measures to alleviate the effects of the 2008 financial crisis on the funding of defined benefit (DB) plans. These measures allowed an employer to instruct a plan’s pension committee to implement one or more of the following measures for the first complete actuarial valuation dated after December 30,… Continue Reading

CAPSA Guidelines re Prudent Investments and Funding Policies

Posted in Canada Pensions & Benefits Law, DB Plan Funding, DC Plans, Investments, Plan Administration

The Canadian Association of Pension Supervisory Authorities (CAPSA) has been working away at providing pension plan administrators with guidance regarding pension plan investing and funding. As we reported earlier, CAPSA released draft guidelines this past spring. Those guidelines were released on November 15, 2011 in final form: Guideline No.6 – Pension Plan Prudent Investment Practices… Continue Reading

CAPSA Agreement re Multi-Jurisdictional Plans – Implications for Ontario and Quebec Administrators

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Plan Administration

Effective July 1, 2011, the administration of Ontario and Quebec registered pension plans with members in both jurisdictions is subject to the Canadian Association of Pension Supervisory Authorities Agreement Respecting Multi-Jurisdictional Pension Plans (the Agreement).  The Agreement sets out a framework for the regulation and administration of multi-jurisdictional pension plans (MJPP), including: The rules of… Continue Reading

Ontario Budget: Pension Reform Will Continue

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Legislation & Regulations, Pension Reform, Plan Administration

In this week’s Budget announcement, the Ontario government confirmed that work continues on its pension reform initiatives. While a number of the government’s announcements focus on the administration, investment and funding of single and multi-employer pension plans, the government also reiterated its desire to make changes at the “macro” level through support of modest phased… Continue Reading

CAPSA Releases Draft Guidelines on Prudence Standard and Funding Policies

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Plan Administration, Regulator Policies & Communications

As we reported in an earlier post, the Canadian Association of Pension Supervisory Authorities (CAPSA) published a consultation paper in late 2009 entitled “The Prudence Standard and the Roles of the Plan Sponsor and Plan Administrator in Pension Plan Funding and Investment”. Following up on this consultation paper, CAPSA recently released draft guidelines on funding… Continue Reading

Ontario Announces Temporary Solvency Funding Relief for Public Sector Plans

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Pension Reform, Public Sector Plans

Late last week, the Ontario government announced that it would provide temporary solvency funding relief to certain public sector and broader public sector (BPS) pension plans. Obtaining such relief, however, will not be an easy matter. The government has made it clear that in an effort to ensure that these plans are sustainable in the… Continue Reading

OSFI Releases Guide re Intervention Process

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Plan Administration, Regulator Policies & Communications

The Office of the Superintendent of Financial Institutions (OSFI) recently released the “Guide to Intervention for Federally Regulated Private Pension Plans” (the Guide), which outlines the varying degrees of scrutiny that federally regulated plan administrators can expect from OSFI and the circumstances under which intervention measures may be taken.

Bill 120 Changes Regarding Pension Plan Funding

Posted in Canada Pensions & Benefits Law, DB Plan Funding, Legislation & Regulations, Pension Reform

In this post, I will discuss important pension plan funding changes implemented by Bill 120, Securing Pension Benefits Now and for the Future Act, 2010. (Previous posts have considered some of the more controversial aspects of Bill 120, namely, changes to the rules regarding surplus withdrawals, contribution holidays and plan expenses.) Like many aspects of… Continue Reading