The Canadian Association of Pension Supervisory Authorities (CAPSA) has put together a draft strategic plan outlining its priorities for 2019-2022.
The CBA’s Pensions and Benefits Law Section generally supports the draft plan and says it commends CAPSA for engaging with stakeholders before finalizing the plan to understand the practical challenges they face.
In a letter to CAPSA the Section makes a number of specific comments on the draft plan, but also makes a few general comments about what the organization’s priorities should be.
For example, encouraging all Canadian jurisdictions to get on board with the Agreement Respecting Multi-Jurisdictional Pension Plans should be one of CAPSA’s top priorities, it says.
“Administrators of multi-jurisdictional plans have faced practical difficulties and uncertainty in administering such plans for many years,” the Section writes. “These challenges increase the cost of administering the plans and potentially prejudice the security of the benefits of plan beneficiaries.”
Priority should also be given to updating the guidelines outlined in the draft plan in order to keep them current and reflective of recent developments and best practices, and to “developing a more coordinated and harmonized approach to address unclaimed benefits.”
As for more specific comments:
- The Section believes CAPSA should solicit stakeholder feedback before issuing any guidance on the use of leverage by pension plans;
- The Section says it would be “helpful and appropriate” for CAPSA to provide regulatory guidance on the use of technology, particularly on the issue of cyber security;
- While priorities 4 and 5 in the draft plan are useful, the Section believes they are not as important as others in the draft plan.