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Ontario Target Benefit Consultation

Dear MEBCO Members and Stakeholders:

On March 15, the Ontario Ministry of Finance issued its proposed permanent framework for target benefits. MEBCO finds the proposed framework deeply flawed and will be meeting with the Ministry of Finance, the Ontario pension regulator (FSRA), other key ministers and politicians within a short time to relay our concerns which are highlighted as follows:

• there is a proposed Provision for Adverse Deviation (PfAD) which closely resembles the one just rejected in British Columbia and under review in Alberta because it is so deeply flawed, highly volatile and was recognized by the Canadian Institute of Actuaries as flawed when introduced in Alberta and British Columbia,

• the proposed framework fails to recognize that target plans already exist in Ontario and are managed by a fiduciary board of trustees,

• It requires disclosure that is unprecedented in the pension environment particularly for jointly sponsored pension plans and single employer pension plans that have similar risks,

• it is essentially the same proposal issued by the Liberal government in 2018 that was soundly rejected by the industry including pension experts, unions, trustees and employers,

• Materials can be found on the Ontario Regulatory Registry at: https://www.ontariocanada.com/registry/view.do?postingId=44107&language=en

About MEBCO

MEBCO was established in 1992 to represent the interests of Canadian multi-employer pension plans (MEPPs) and benefit plans (MEPs) with provincial and federal governments regarding proposed or existing legislation and policies affecting these plans. MEBCO is a federal no-share capital corporation, operating on a not-for-profit basis.

MEBCO is representative of all persons and disciplines involved in MEPs, including union and employer trustees, professional third-party administrators, non-profit or "in-house" plan administrators, professionals including actuaries, benefit consultants, lawyers, and chartered accountants. MEBCO is administered by a Board of Directors consisting of representatives from each of the above groups. MEBCO represents all stakeholders in target benefit multi-employer pension plans (MEPPs) – employers, unions, and professionals.

Multi-employer pension plans (MEPPs) are typically administered by a board of trustees. The trustees in most MEPPs are appointed by some combination of the trade union(s) representing plan members and employer association(s) representing the participating employers. Both the trade unions and the employer associations are not-for-profit organizations with limited resources. The trade unions and the employer associations typically receive most of their funding through dues payable in accordance with the applicable collective agreements. 

Yours truly,

Alex McKinnon
President

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