The Pensions and Benefits Law Section of the Canadian Bar Association commends the Canadian Association of Pension Supervisory Authorities, or CAPSA, for engaging stakeholders as it finalizes its 2023-2026 Strategic Plan.
The CBA Section is particularly pleased with CAPSA’s intention to continue its proactive efforts towards greater harmonization of principles and practices. “We appreciate the difficulty in achieving consensus on these issues across all jurisdictions in Canada,” the letter reads. It offers a few more detailed recommendations that are summarized below.
It’s important to have clear guidelines on decumulation of defined contribution account balances and to keep those guidelines regularly updated. The CBA letter supports CAPSA’s proactive approach on this subject.
It also comments positively on the updated Guideline No. 3 on Capital Accumulation Plans’ near completion and notes a similar process should be followed for decumulation. The CBA Section notes it “would be pleased to participate in future consultations on this issue, including on variable payment life annuities,” as was introduced in an earlier submission to Finance Canada.
The CBA Section is also eager to provide feedback on CAPSA’s new inclusive Risk Management Guideline, especially on the role of ESG (environmental, social and governance) in pension plan management and investment, as well as cybersecurity and the use of artificial intelligence in pension plans. “We continue to encourage the adoption of coordinated and harmonized practices where possible,” the letter reads.
The CBA Section is happy with CAPSA’s engagement at the national and international levels and encourages it to promote and maintain a robust engagement process with the pension sector at large, “both through public consultations and involvement with industry working groups and the Joint Forum of Financial Market Regulators.”