August 02, 2022
The Association of Canadian Pension Management (ACPM) says that a single risk management framework for the diverse areas regulated by the Office of the Superintendent of Financial Institutions (OSFI) is not appropriate given the different regulatory needs and structures of each.
In a July 15th submission, ACPM says initiatives undertaken by OSFI that signal a move toward a uniform approach to risk management across the diverse areas OSFI regulates, have the potential to not accurately, nor fully reflect, the legal and other differences among banks, insurance companies and pension plans.
ACPM recommends that OSFI adopt separate policies and guidance for each of the areas it regulates to better ensure that the differences are respected and properly reflected in its policies and guidance.
You can read ACPM’s full submission here: