Document Properties
- Type of Publication: Letter
- Date: March 27, 2020
- To: Federally Regulated Private Pension Plans
As a result of the COVID-19 crisis, OSFI has made adjustments to its policies to protect the interests of pension plan members and beneficiaries and to allow administrators of federally regulated private pension plans to focus their efforts on addressing the many challenges posed by this crisis, including its impact on financial markets.
Full freeze on portability transfers
OSFI has revised the Directives of the Superintendent pursuant to the Pension Benefits Standards Act, 1985 effective March 27, 2020 to implement a full freeze on portability transfers and annuity purchases relating to defined benefit provisions of pension plans. Transfers and annuity purchases are being prohibited at this time to protect the benefits of plan members and beneficiaries, given that current financial market conditions have negatively affected the funded status of pension plans. The payment of pensions to retirees and other beneficiaries is not impacted by the freeze on portability transfers and annuity purchases. We will review this temporary measure in the coming months as we continue to monitor the impact of this crisis on defined benefit pension plans. During the temporary freeze period, administrators may request the Superintendent's consent to a transfer or annuity purchase based on plan-specific or special circumstances.
Extension of filing deadlines
OSFI is extending the deadlines for certain actions and annual filing requirements under the Pension Benefits Standards Act, 1985 (PBSA) and the Pooled Registered Pension Plans Act (PRPPA), as detailed in the following table.
| Action or Required Filing | Deadline | Revised Deadline |
|---|
| PBSA reporting requirements |
|---|
| Annual Information Return (OSFI 49) including the Schedule A – Canada Revenue Agency Information Requirements (OSFI 49A) and the Pension Plan Annual Corporate Certification (PPACC) | 6 months after plan year-end | 9 months after plan year-end
OSFI will issue an invoice for the annual assessment after this extended deadline. |
| Certified Financial Statement (OSFI 60) | 6 months after plan year-end | 9 months after plan year-end |
| Auditor's Report Filing Confirmation (ARFC) | 6 months after plan year-end | 9 months after plan year-end |
| Actuarial Report and Actuarial Information Summary (AIS) and, if required, Replicating Portfolio Information Summary (RPIS) | 6 months after plan year-end | 9 months after plan year-end |
| Annual statements to members and former members and spouses or common-law partners | 6 months after plan year-end | 9 months after plan year-end
To manage expectations, administrators should notify recipients of the delay. |
| PRPPA reporting requirements |
|---|
| Pooled Registered Pension Plan Annual Information Return (includes financial statements) | April 30
(4 months after plan year-end) | July 31
(7 months after plan year-end) |
| Pension Plan Annual Corporate Certification (PPACC) | April 30
(4 months after plan year-end) | July 31
(7 months after plan year-end)
OSFI will issue an invoice for the annual assessment after this extended deadline. |
|
Suspension of consultation initiatives and policy development
OSFI has suspended a number of consultation initiatives and policy development work related to new or revised guidance until conditions stabilize. The pension-related documents affected by this measure are listed below.
Plan administrators should be proactive in informing their OSFI Relationship Manager of any financial or operational challenges they encounter. We continue to actively monitor the financial environment. If OSFI decides to further modify its supervisory or reporting requirements, plan administrators will be notified in a timely manner.