On November 29, 2019, OSFI published InfoPensions - Issue 22. The publication introduces some revisions to the annual regulatory returns applicable to pension plans. Here’s a summary of some of these key changes:

Updated returns for regular annual filings

OSFI has made changes to some of its annual regulatory returns applicable to pension plans registered under (or having filed an application for registration under) the Pension Benefits Standards Act, 1985.

The revision to these returns aims to:

  • remove duplicate or unnecessary data,
  • make the information reporting simpler, more efficient and more consistent, and
  • to include additional information that will improve OSFI’s supervision of pension plans.

OSFI has amended the following returns:

  • Solvency Information Return (OSFI 575),
  • Annual Information Return (OSFI 49) and its accompanying Schedule A,
  • Certified Financial Statements (OSFI 60),
  • Pension Plan Annual Corporate Certification (PPACC).

Also, OSFI has developed a new Auditor’s Report Filing Confirmation (ARFC) return. All plans must complete the ARFC return. It includes four questions (see below). This return will allow each plan to confirm whether they need to file an Auditor’s Report, and to upload the report if required. A plan does not have to submit an Auditor’s Report if the response to any of the following questions is “Yes”:

  1. Are all assets of the pension funds held by one insurance company in any type of account?
  2. Are all assets of the pension fund held in the pooled funds of one trust company?
  3. Are all assets of the pension fund held by one trust company but not in its pooled funds, and the fair market value of the total assets of the pension fund is less than $5,000,000?
  4. Is the plan a fully insured plan (i.e. all benefits are paid by means of an annuity or insurance contract)?

All other plans are required to upload an Auditor’s Report to be able to submit their return in the Regulatory Reporting System (RRS).

The OSFI will update and re-issue the accompanying instruction guides according to these changes. The OSFI has already updated the guide pertaining to the Solvency Information Return. It is available here. The other instruction guides will be available on the OSFI website by Spring 2020.

What action is required?

Sun Life remains committed in adapting to regulatory and legislative changes. We have processes in place to support these changes in a proactive and timely manner. This communication is for your information only. You may refer to InfoPensions for details regarding important filing dates and requirements.

Questions?

Please contact your Sun Life Group Retirement Services representative.