The Financial Services Commission of Ontario (FSCO) recently undertook a review of the pension plan contribution reporting and monitoring processes. FSCO would like to streamline information collection from pension fund trustees to efficiently monitor contributions and respond effectively to notifications regarding non-remittances and variances.
The Pension Benefits Act (PBA) and Regulation 909 (Regulation) require:
1. the pension plan administrator to:
- provide the trustee(s) of the pension fund with a summary/revised summary of contributions in a form (Form 7) approved by the Superintendent of Financial Services (Superintendent), within prescribed periods (section 56.1(1) of the PBA, sections 6.2(2) and 6.2(3) of the Regulation);
- notify the Superintendent, in the prescribed manner and within the prescribed period, if a contribution is not paid when due* (section 56(2) of the PBA);
2. the trustee(s) of the pension fund to:
- notify the Superintendent, in the prescribed manner and within the prescribed period, if a Form 7 is not received (section 56.1(2) of the PBA and section 6.2(4) of the Regulation); and,
- notify the Superintendent if a contribution is not paid when due, within the prescribed period (section 6.2(5) of the Regulation).
FSCO reviewed Form 7, the existing processes for pension fund trustees to report non-receipt of Form 7, and the type of information currently provided to notify FSCO regarding contribution non-remittances/variances. FSCO also considered feedback from stakeholder consultations.
Based on this review, FSCO will implement the following changes:
- FSCO Form 7 – Summary of Contributions/Revised Summary of Contributions.
FSCO has developed a comprehensive User Guide for Form 7, to help pension plan administrators complete each section of the Form. The User Guide also clarifies the situations in which a ‘Revised Form 7’ is to be submitted to the pension fund trustee(s). Wherever possible, FSCO has included examples to provide additional clarity. The updated FSCO Form 7 and corresponding User Guide will be available on FSCO’s website.
FSCO has developed two new standardized templates, to be used by pension fund trustees:
- Non-Remittances/Variances Reporting Summary - to report non-remittance and variance of contributions to the pension fund, for each applicable plan.
- Non-Receipt of Form 7 Summary - to report non-receipt of the Form 7 for each applicable pension plan.
The Reporting Summaries will allow trustees to consolidate and transmit information easily. The Reporting Summaries will streamline reporting, improve the quality of data provided, enhance contribution monitoring and create efficiencies in responding suitably for each reported instance. The Reporting Summaries will be available on FSCO’s website.
FSCO recommends pension fund trustees use these standardized Reporting Summaries to report non-receipt of Form 7 and contribution non-remittances and/or variances to FSCO.
FSCO welcomes comments and recommendations on these changes, by email to: firstname.lastname@example.org.
* There is no standardized reporting currently available for plan administrators to notify the Superintendent when contributions are not paid when due. FSCO will look at approaches on how to do this, at a later date. Plan administrators should continue to provide these notifications by e-mail.