OSFI Actions to Address Issues Stemming from COVID-19

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 FilingDeadlineRevised DeadlineTable footnote *
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)Table footnote **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)Table footnote ** 6 months after plan year-end9 months after plan year-end
Auditor’s Report Filing Confirmation (ARFC)Table footnote **6 months after plan year-end9 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-end9 months after plan year-end
Annual statements to members and former members and spouses or common-law partners6 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.

Footnotes

Footnote *

Applicable only to actions or required filings listed hereunder for plans with a year-end between September 30, 2019 and March 31, 2020.

Return to table footnote *

Footnote **

An updated instruction guide for filing this return will be made available on OSFI’s website on March 31. The revised deadline provided in this table supersedes the filing due date found in the updated instruction guide for plans with a year-end between September 30, 2019 and March 31, 2020.

Return to table footnote **

Suspension of consultation initiatives and policy development Footnote 1

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.

OSFI GuidanceAdditional Details
Policy consultations
Instruction Guide for the Preparation of Actuarial Reports for Defined Benefit Pension Plans (due on March 20, 2020) Consultation suspended until further notice. We will continue to review submissions already received and will welcome any submission during this suspension period.
Instruction Guide for the Termination of a Defined Benefit Pension Plan (due on March 31, 2020)
Posting of final guidance
Instruction Guide for Authorization of Amendments Reducing Benefits in Defined Benefit Pension Plans and non-attributed summary of comments received along with OSFI’s responses Posting delayed until further notice. We will continue to review submissions received.

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.

Footnotes

Footnote 1

For more details please see OSFI’s March 13, 2020 release.

Return to footnote 1