The Voice of Multi-Employer Plan Interests in Canada

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MEBCO's primary activity is to monitor and assess the impact of legislative reforms that affect Canadian multi-employer pension and benefits plans. In many cases, we advocate our position through written submissions to government, and regulatory and administrative agencies.

To view a submission, just click on a title of interest from the list below. In the interest of avoiding repetition, we have deleted standard introductory remarks that provide background information on MEBCO from many of these documents.

Documents that are presented as Adobe Acrobat PDF files require Adobe Acrobat reader to properly view. If you would like an original copy of any of these submissions, you can obtain one by contacting MEBCO.

Honourable Minister Joe Ceci
President of Treasury Board, Minister of Finance
Office of the Minister
Treasury Board and Finance
323 Legislature Building
10800 - 97 Avenue
Edmonton, AB T5K 2B6

Brussels, the 24th of March 2017

Re: Letter of support of the World Pension Alliance to the MEBCO position on the Target Benefit Legislation for Collectively Bargained Multi-Employer Pension Plans (CBMEPPS)

Dear Honourable Minister Ceci,

The World Pension Alliance (WPA) is a collective organization representing the interests of over 200 million members of pension plans registered in jurisdictions around the World. Our membership includes the Multi Employer Benefit Council of Canada (MEBCO) along with the AEIP (European Association of Paritarian Institutions of Social Protection) and PensionsEurope of Europe; the NCCMP (National Coordinating Committee for Multiemployer Plans), the ABC (American Benefits Council), the NCPERS (National Conference On Public Employee Retirement Systems) of the United States of America; the FIAP (International Federation of Pension Fund Administrators) of Latin America; and ASFA (Association of Superannuation Funds of Australia) of Australia.

MEBCO has communicated with us regarding its March 8, 2017 submission and this has been discussed by the WPA executive.

On behalf of the WPA we confirm that we fully endorse and support MEBCO’s position as communicated in its March 8th letter. We hope you will treat the matter with great urgency.

Best regards
Bruno Gabellieri
Chairman
World Pension Alliance
AEIP, Rue Montoyer 24, 1000 Brussels (Belgium)

March 8th, 2017
Honourable Minister Joe Ceci
President of Treasury Board, Minister of Finance
Office of the Minister
Treasury Board and Finance
323 Legislature Building
10800 ‐ 97 Avenue
Edmonton, AB T5K 2B6

Re: Target Benefit Legislation for Collectively Bargained Multi‐Employer Pension Plans (CBMEPPS)

Dear Honourable Minister Ceci,

The Employment Pension Plans Act (EPPA) requires that persons who terminate employment be offered a lump sum payment in lieu of a pension. As you know the current rules for calculating the lump sum payment create an imbalance between what the terminating person could be paid and the assets the applicable pension plan has in reserve for that person. The application of the EPPA rewards the terminating person for taking his/her pension away from the Alberta‐registered plan and financially punishesthe pension plan. Simply put the terminating person takes almost twice the reservesthe pension plan holds for that person’s benefit; the remaining members of the plan bear the burden of this cost. This puts the remaining members in the pension plan at risk of significant benefit reductions.

Your government and previous governments have been asked to correct this inequity. So far, no action has been taken, beyond our meeting with your officials who are alive to the issue but who are seemingly powerless to carry what is a minor and almost inconsequential ‘fix’.

This unresolved matter is now creating a crisisfor CBMEPPsregistered in Alberta and negatively impacting over 175,000 pension plan members. Based on the information we have it is possible that inaction on this matter will put most of Alberta’s 22 CBMEPPs in a cash crisis in the next year. This will be headline news as these plans will be forced to reduce benefits, including benefits to retired persons, in order to preserve cash.

Some CBMEPPs already report having to change their long‐term asset mix to allow for payment of lump sumsto terminating persons. Thisimpactsthe long‐term viability of these plans. Without adequate action these knock‐on effects will resonate for a long time to come.

We stress that the terminating persons have the right to keep their pension in the applicable plan. They should also be allowed to take a lump sum payment from the plan representing the appropriate value of their benefit. Unfortunately, a whole financial industry has been built around encouraging terminating persons to take the lump sum commuted value calculated under the EPPA because it is a windfall for the terminating person (and his/her financial advisor).

We are urging you in the strongest possible termsto take action now to correct the EPPA so that CBMEPPs can be preserved. Staff in your Ministry have advised us that the amendment to the EPPA is to only two lines. We are willing to work with your government quickly to resolve this crisis and preserve the 22 Alberta‐registered CBMEPPs.

Requesting your most urgent action,
Robert R. Blakely QC
President

March 21, 2016

 

Via E-mail

Pension Policy Branch

Ministry of Finance

Asser Transfers - MEPPs

7 Queen’s Park Crescent 

5th Floor, Frost Building South

Toronto, ON  M7A 1Y7

 

Dear Madam or Sir:

Re: Proposal Number 16-MOF004, Amendments to Ontario Regulation 310/13 - Asset Transfers under Sections 80 and 81 of the Pension Benefits  Act

 

MEBCO was established in 1992 to represent the interests of Canadian multi-employer pension 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.  We agree that MEPPs do not fit well into the traditional   single employer regulatory model, and generally support the creation of a MEPP-specific regulatory framework.

 

MEBCO welcomes the recent amendments to the Pension Benefits Act ("PBA") that  would  expressly permit mergers of multi-employer pension plans ("MEPPs"). We understand that the amendments to the PBA expressly permitting MEPP mergers will not come into effect until regulations addressing such mergers are enacted. Therefore, we are pleased that the government is moving forward to develop regulations to permit MEPP mergers and has released draft amendments to Ontario Regulation 310/13 to address the merger of MEPPs (the "Draft Regulations"). We have reviewed the Draft Regulations and are writing to provide you with some comments on  them.

MEBCO RESPONSE TO SASKATCHEWAN FINANCE AND CONSUMER

AFFAIRS AUTHORITY CONSULTATION PAPER: “PROPOSED

REGIME FOR NEGOTIATED COST PENSION PLANS”

 

June 14, 2016

 

Tami Dove

Senior Policy Analyst, Pensions Division

Financial and Consumer Affairs Authority

Suite 601, 1919 Saskatchewan Drive

Regina SK S4P 4H2

Via email: This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Dear Ms. Dove:

MEBCO was established in 1992 to represent the interests of Canadian multi-employer pension

and benefit plans (MEPs). We consult 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 trustees

(union, independent, professional and employer), professional third party administrators, non

profit or “in-house” plan administrators, professionals including actuaries, benefit consultants,

lawyers, investment managers, investment counsel and chartered public accountants. MEBCO is

administered by a Board of Directors consisting of representatives from each of the above

groups. The Board of Directors serve MEBCO on a volunteer basis, and are responsible for

identifying issues that impact MEPs, developing a strategy to address those issues, and then

carrying out the strategy. MEBCO’s member-plans provide comprehensive health coverage to

over 1,000,000 Canadians.

October 26, 2015

Via E-Mail

Canada  Revenue Agency

E-mail:  This email address is being protected from spambots. You need JavaScript enabled to view it.


Dear  Sirs/Mesdames:

Re: Submissions of the Multi-Employer Benefit Plan Council of Canada Regarding Income Tax Folio S2-Fl-Cl: Health and Welfare Trusts.

The Multi-Employer Benefit Plan Council of Canada (MEBCO) is a federal no-share capital corporation operating on a not-for profit basis representing the interests of Canadian multi­ employer pension and benefit plans with respect to proposed or existing legislation and policies affecting these plans.

We are writing to submit our comments with respect to the Canada Revenue Agency's (CRA's) recent draft Income Tax Folio S2-Fl-Cl concerning the taxation and regulation of Health and Welfare  Trusts (HWTs).

 

About MEBCO

MEBCO was established in 1992 to represent the interests of  multi-employer  benefit  plans  (MEPs) in Canada. MEBCO advocates on behalf of all stakeholders involved  with  MEPs, including union and employer trustees, independent and professional trustees, professional  third party administrators, non-profit or "in house" plan administrators and professionals including actuaries, benefit consultants, lawyers, investment managers, and chartered  professional  accountants. MEBCO's Board of Directors is composed of volunteer representatives of  these  groups, and is responsible for identifying, addressing, and advocating with respect to all issues impacting  multi-employer  plans  in Canada.

 

Background on Multi-Employer Plans

Multi-employer plans are essential to over one million workers and their families in industries including construction, food service, retail, hotel and restaurant, graphic arts, garment manufacturing, security, textiles, transportation and entertainment. MEPs are a response to the difficulties of delivering quality health care services, disability and other income replacement benefits and life insurance to workers and their families in industries typified by small employers and mobile work  forces. These plans  ensure that  seamless benefit  coverage  is provided  to workers  and their families as they move from one contributing  employer  to the next. This  seamless coverage is especially  important  in mobile  and/or  seasonal  industries where  it is often expected that workers will be employed by multiple employers in a single year and/or may experience significant periods of non-employment or disability. In these industries, it is not uncommon for a worker to be employed by one employer for a matter of days or weeks before moving on to a different project with a different employer. A centralized MEP ensures these workers have access to necessary benefit coverage regardless of the sometimes intermittent nature of these work relationships.

In addition to providing seamless benefit coverage, MEPs are economically efficient in the sense of providing economies of scale by bringing together large numbers of smaller employers who receive financial savings in respect to administration and the purchasing of benefits. In other words, the pooling of collectively bargained contributions in these industries is beneficial both to workers and smaller employers who may wish to extend benefit coverage to their workers.

MEPs are generally administered by an independent joint board of trustees, comprised of an equal number of trustees appointed by the participating union or unions and employer bargaining associations. As with any trust, the MEP trustees owe a fiduciary obligation to act in the best interest of the trust beneficiaries, not the sponsoring employers or unions. The trustees do not determine the contribution rates, which are negotiated between the employers and the unions as part of the collective bargaining process. The contribution rates are typically based on hours worked.

MEPs deliver what are effectively public health care services and related benefits through privately funded vehicles. Without MEPs, millions of Canadians would not have access to these supplementary benefits, the cost of which would otherwise be borne by the government and Canadian taxpayers.

 

Joining MEBCO

Five reasons why your MEBCO membership is critical
Your MEBCO membership guarantees that multi-employer plan interests will be considered whenever change is on the horizon. With your support, MEBCO will continue to be a strong and effective voice. Join today!
  1. The threat to multi-employer plans is real.
    The legislative framework is constantly changing, and cost-management and cost reduction are at the top of every agenda.
  2. Legislative changes can be significant.
    Recent proposed changes have threatened to offload costs onto plans, restrict plan coverage, and have compromised the viability of some plans
  3. Multi-employer plans are worth protecting.
    Multi-employer plans play a vital role in providing health services and retirement plans to over 1 million workers and their families in industries typified by small companies and a mobile work force.
  4. Multi-employer plans need a united lobby.
    Multi-employer plans carry a low profile due to the fact that the coverage is thinly spread over many employer groups and mobile workers.
  5. MEBCO is committed to protecting your interests.
    When governments propose changes, MEBCO is the single, clear voice at the table representing the unique interests of multi-employer plans.