Targeted Review: Form 7 – Contribution Reporting & Monitoring Process

​​The contribution reporting and monitoring process is an important tool that helps FSCO become aware of any non-remittance and contribution variances.

 

Pension legislation requires that pension plan administrators complete a Summary of Contributions / Revised Summary of Contributions (Form 7) and file it with the pension fund trustees. Further, it requires pension fund trustees (persons who are prescribed for the purposes of subsection 22(6) of the Pension Benefits Act) to notify the Superintendent of Financial Services within the prescribed period if they do not receive a Form 7, or if a contribution is not paid when due.

 

In November 2016, FSCO implemented changes to the contribution reporting and monitoring process. We published a comprehensive User Guide to help administrators accurately complete Form 7 and introduced standardized Reporting Summaries for use by pension fund trustees.

 

In November 2017, FSCO launched a targeted review of 168 DB and 75 DC plans (DB included some combination plans) to determine whether:

 

  • administrators are completing Form 7 correctly; and
  • ​pension fund trustees are reporting non-remittances and/or variances.

Findings

FSCO’S TARGETED REVIEW OF THE FORM 7 PROCESS 

Description of infographic for FSCO's targeted review of Form 7 [New Window]

 

Notes:
“Contributions not correctly remitted to the fund” includes contributions not made within the prescribed timelines and/or the incorrect contribution amount.

 

“Non-remittances or variances not reported to FSCO” relates only to plans under the review that had contributions not correctly remitted to the pension fund.

 

Regulatory Action

 

FSCO has reported compliance issues found during the course of the review to the administrator responsible for immediate action.

 

Non-remittance of funds (missing contributions) is a serious violation that reduces benefit security for pension plan beneficiaries. Failure to report non-remittance or variances accurately to FSCO will result in increased regulatory scrutiny and action from FSCO.

 

Important Reminders to Administrators

 

  • Use the updated Form 7 which is available on FSCO’s website
  • Review the user guide to ensure you understand the process, timelines and responsibilities.
  • Resolve any issues brought to your attention by the pension fund trustee quickly and effectively
  • File all up-to-date plan documentation with FSCO including plan amendments, collective agreements, contact information, etc.
  • Respond to inquiries and requests from FSCO by the due date provided.

Important Reminders to Pension Fund Trustees

 

  • Review all forms carefully to identify issues such as missing or incorrect information, and report those errors to the Administrator promptly.
  • Report all missing or late contributions to FSCO, even if contributions are made later to ‘catch up’
  • Use the tools provided by FSCO such as the User Guide and Reporting Summa​ries to help make the process smoother and improve the quality of data you provide.

FSCO’s next steps

 

  • Outreach to pension fund trustees regarding the Form 7 process, requirements and opportunities for improvement.
  • Increase monitoring and enforcement activities for administrators, trustees and custodians who do not report missing or late contributions
  • Explore changes to the Form 7 reporting and monitoring processes to make it more effective

More information

 

3rd Quarter Update - Estimated Solvency Funded Status of Defined Benefit Plans in Ontario
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