Expectations for submissions to support timely closure of action items

The purpose of this communication is to support the timely closing of action items by sharing our expectations for submissions of evidence by federally regulated financial institutions (institutions) and federally regulated pension plans (pension plans).

Introduction

When we identify issues of significance through our supervisory work, we communicate findings and related action items. Findings reflect matters we deem to be significant and represent a shortcoming, deficiency, or weakness. Through supervisory letters, we articulate the issues underlying a finding, why it matters to remediate the issues, and the recommended action item. Frequently, we explain the identified issues through references to expectations articulated in relevant legislation, regulations, and guidelines.

Principles-based supervision

We strive to be principles-based in our communications of the institution-specific finding, why  it matters, and the recommended action item. We do not provide prescriptive instructions as to how an institution or pension plan administrator should remediate an issue. Similarly, we do not set out a detailed or exhaustive list of steps to resolve an action item.

At times, the principles-based nature of our supervisory practices, in particular how we articulate findings and related action items, might result in longer closure timelines. Thus, we prepared this communication to articulate our expectations for the contents of submissions that can contribute to more expeditious closing of action items.

Submissions for closure of action items

Institutions and pension plans administrators should carefully review the description of each finding and the related action item. Findings clearly describe the deficiencies identified. To close an action item, we seek evidence that the institution or pension plan administrator effectively and sustainably addressed the identified shortcomings.

Submissions should be aligned with the previously agreed action plan. Any significant changes to that plan should be discussed with, and agreed to by, the lead supervisor before the institution or pension plan administrator submits evidence for closure.

The submission should contain a detailed description of what the institution or pension plan administrator did in response to our recommended action item. If the action item contained multiple parts, then the institution or pension plan should submit details for each part of the recommended action item. We seek evidence of effective implementation and details about how the institution or pension plan administrator will sustain such remediation.

Institutions and pension plan administrators should only submit evidence for closure of action items once remediation is complete. Partial or interim submissions should not be provided unless explicitly requested and agreed in advance with the lead supervisor. If this means that the institution or pension plan administrator will not meet the agreed target date for completion, notify the lead supervisor to discuss revised timelines rather than submit a partially complete resolution.

Submissions should focus on outcomes that directly address the action item. Institutions and pension plan administrators should avoid materials that do not demonstrate effective remediation. For example, do not submit operational artifacts or supporting documentation such as copies of calendar entries, email notifications, internal newsletters, or intranet communications. Our assessment focuses on what the institution or pension plan administrator achieved, not on implementation mechanics.

Where we provided feedback on a prior submission to close an action item, any subsequent submission should clearly address that feedback. If the institution or pension plan administrator seeks further clarification, they should contact their lead supervisor before any new submission.