Consistency in language and harmony in legislation are positive steps as the federal government continues its task of amending pension plan legislation.
The CBA National Pensions Section wrote in May to the Finance Department to comment on proposed changes to the Pension Benefits Standards Regulations, 1985, and the Pooled Registered Pension Plan Regulations published in the Canada Gazette Part I on April 29.
“The CBA Section commends the government’s continuing efforts to address important pension plan funding issues and to make technical changes to pension legislation where required,” the Section writes. “We also appreciate the government seeking input from pension industry stakeholders on proposed legislative changes.”
One change to the PBSR, the Section notes, would change the letter of credit limit from 15 per cent of a plan’s assets to 15 per cent of its solvency liabilities, which would bring the national letter of credit limit in line with limits in several provinces. “As we have long advocated harmonization of pension legislation across Canada, we believe that these proposed changes are a positive step,” the Section says.
For the sake of consistency, the Section suggests a pair of technical amendments to the PBSR which would deal with the ability of survivors to transfer funds from locked-in RRSPs and from deferred life annuities, to provincially regulated plans, excepted plans and pooled registered pension plans on the death of the holder.
The Section also points out an inconsistency in language between the English and French versions of the Pension Benefits Standards Act section 4(2).