Targeted Review: Form 7 – Contribution Reporting & Monitoring Process

Archived Content

The following content was archived on October 2018, and is provided for historical reference. Information is subject to change and may no longer be accurate.

 

 

 

 

​​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 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.

 

FSCO launched a targeted review in November 2017 to focus on whether:

 

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

More information

Frequently Asked Questions: Targeted Review – Form 7

 

Q1. I received a letter in the mail from FSCO about information relating to Form 7. What does this mean?

 

A1.  FSCO is conducting a targeted review related to Form 7 to ensure compliance with the Pension Benefits Act (PBA) and FSCO policies, and to protect the interests of pension stakeholders by promoting best practices. You received a letter because your plan has been selected to be part of the review.  

 

Q2. How long do I have to respond to this request from FSCO?

 

A2. You have 30 days from the date of the letter to respond to this request from FSCO. This timeline is noted in the letter itself. FSCO may contact you before the 30 days to ensure a response is forthcoming.

 

Q3. What is Form 7 – Summary of Contributions?

 

A3. Pension plan administrators must provide their pension fund trustee(s) with an annual forecast of the required monthly contributions to be remitted to the pension fund (section 56.1(1) of the PBA). They are required to provide this ‘summary of contributions’ within 60 days of the beginning of a plan’s fiscal year.

 

If there is any subsequent change to this summary of contributions, the administrator must inform the trustee about the change by submitting a revised summary of contributions within 60 days of the change.

 

This summary – both the initial summary of contributions and the revised summary of contributions – must be provided in a Superintendent-approved form (i.e. Form 7).

 

Section 6.2(5) of the Regulation provides that if a contribution is not paid when it becomes due, the trustee(s) of the pension fund must notify the Superintendent within 60 days after the date on which the contribution became due.

 

If the plan administrator does not submit a Form 7 by the due date, section 56.1(2) of the PBA and section 6.2(4) of the Regulation require the trustee(s) of the pension fund to notify the Superintendent within 30 days after the day on which the summary was required to be given.

 

FSCO uses Form 7, along with the Reporting Summaries introduced in November 2016, as key elements in its contribution reporting and monitoring process. To ensure this process is working effectively, FSCO has requested the information outlined in the letter you received.

 

If you are not aware of the Form 7, or have never submitted one, please contact the staff member indicated at the bottom of the letter for assistance.

 

Q4. What are the non-remittance reporting summaries related to the Form 7 filing and why should the custodian/trustee use them?

 

A4. The two non-remittance reporting summaries are standardized templates, to streamline reporting and improve the quality of data that pension fund trustee(s) provide to FSCO: 

 

  • 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 Reporting Summary: to report non-receipt of Form 7 for each applicable pension plan.

The non-remittance reporting summaries are published on FSCO’s website along with the revised Form 7 and User Guide.

 

FSCO sent an email to all plan administrators and trustees on November 18, 2016, providing a detailed explanation about the contribution reporting and monitoring process.

 

Although these non-remittance reporting summaries are not mandatory at this time, FSCO strongly encourages their use.

 

Q5. My pension plan has an off-cycle fiscal year (i.e. not a calendar year of January through December 2017). What fiscal year information should I provide in response to your request?

 

A5. FSCO requests that you provide the information for the first six months from the start of your plan’s fiscal year. For example:

 

  • if your pension plan’s fiscal year begins on December 1, you should provide information from December 1, 2016 to May 31, 2017; or
  • if your pension plan’s fiscal year begins on February 1, you should provide information from February 1, 2017 to July 31, 2017.

 
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