ACPM responds to Ontario government's request for comments on proposed regulations for implementing Target Benefit Plans framework
September 09, 2024
The Association of Canadian Pension Management (ACPM) has responded to the Ontario government's request for technical comments on proposed regulations for implementing a permanent framework for Target Benefit Plans (TBPs). The ACPM suggests that the Ontario government consider less prescriptive requirements.
In its open letter, the ACPM noted that the proposed regulations introduce stricter TBP requirements than those in other jurisdictions, potentially leading to higher costs and lower benefits for members. The ACPM believes these strict regulations are unnecessary and could negatively impact TBPs.
Specifically, the ACPM urges the Ministry of Finance to justify the substantive codified elements in the new governance, funding and communication policy requirements, as they could add unnecessary red tape and costs, reducing funds available for benefits. The ACPM highlights that other jurisdictions with governance and funding policy requirements are less prescriptive and typically do not require filing with the regulator, and no jurisdiction mandates the preparation or filing of a communication policy.
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