Response to OSFI on its Guide for Preparation of Actuarial Reports for DB Plans 

On October 13, 2020, PIAC commented on OSFI’s proposed Instruction Guide for the Preparation of Actuarial Reports for Defined Benefit Pension Plans. PIAC outlined in detail its concerns regarding changes in the determination of liability values using the replicating portfolio approach, and a supervisory cap on the going concern discount rate. Both issues particularly impact PIAC’s federally regulated plans. PIAC questioned the timing of both proposals, which put further pressure on resources at a time when the cash could be reinvested in businesses and the economic recovery. PIAC re-iterated the urgent need to reform pension funding rules at the federal level, which PIAC has sought for many years, given the record low interest rates and weak growth outlook due to COVID-19. PIAC urged the federal government to follow the direction of the larger provinces by moving to a single going-concern funding regime.

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Response to FSRA's Consultation on Missing Members 

On September 16, 2020 PIAC commented on FSRA's draft Principles and Practices Regarding Missing Members. PIAC supported the transfer of unlocatable members’ assets on plan wind up and automatic small benefit unlocking where FSRA has appointed an administrator. The increase of the small benefit threshold and a discharge for benefits of missing members at a certain age was recommended. PIAC advocated for a vehicle that allows plans to send money on behalf of unlocatable members so that the responsibility for these benefits rests with a government entity such as the Bank of Canada. PIAC encouraged the creation of a missing member registry and information sharing arrangements with governments. A waiver on sending statements for missing retired members would alleviate an administrative burden, but PIAC questioned the need for a waiver, since sending confidential pension information to an incorrect address may contravene the administrator’s duty of care

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PIAC's Response to the Consultation on Modernizing Ontario's Capital Markets

On September 7, 2020 PIAC commented on the draft recommendations of Ontario’s Capital Markets Modernization Taskforce. PIAC supported:
- Streamlining and consolidating disclosure
- Electronic delivery of documents required to be published under securities law requirements
- Improving corporate board diversity
- Requiring an annual advisory vote on executive compensation and Say on Pay
- Enhanced disclosure of material ESG information

PIAC opposed introducing a regulatory framework for proxy advisory firms and informal procedures to exclude shareholder proposals.
The submission outlined in detail the reasons for PIAC’s positions.

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PIAC Responds to NS PBA Regulations
 

On July 6, 2020 PIAC responded to the new Nova Scotia Pension Benefits Act Regulation. PIAC commends the Nova Scotia government for moving forward on the majority of the changes originally set out in The Road Forward released last summer Including the introduction of an 85% solvency standard with enhanced going concern funding, as well as the incorporation of the federal PBSA investment rules by reference. However, solvency reserve account regulations appear to only permit access to the reserve account funds on plan wind-up. PIAC believes that flexible reserve account structures, which allow for access if certain funding thresholds are met, will best encourage sponsors to make use of such accounts. While supporting the general approach to the PfAD determination, PIAC believes that there is some optimization that should be considered over time. PIAC believes that CAPSA would be well placed to review with industry participation the various approaches that have been taken and recommend a standardized template in terms of the classification of assets and the provision applied at different allocation levels.

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PIAC Crosses the 100 Volunteer Mark

Simon Fréchet, Chair of the Pension Investment Association of Canada, has welcomed  John McNair, MSc.  as PIAC’s newest volunteer. McNair has volunteered to serve on the Risk Management Committee. This is the first time in its 43 year history that PIAC has more than 100 volunteers active at the same time. Working in a diverse variety of committees, these volunteers are responsible for executing advocacy efforts, creating resources across pension administration, governance and investment areas, and developing education and networking events from coast to coast. In recent years the areas of activity have grown to cover DC plans, responsible investment, risk, tax, legal and more.

“PIAC was created as a self-help organization and with the tremendous growth and complexity of the pension sector, our members have continued to step up to share, connect and create,” said Fréchet. “Our volunteers tell us they get tremendous value from participating with peers from across types, sizes and geographies of plans.”

McNair has a long history with the pension sector, currently as Vice President, Investment Risk Management & Analytics at the Investment Management Corporation of Ontario and previous roles at the Ontario Pension Board and OMERS.

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