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.

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.

 

 

MULTI-EMPLOYER BENEFIT PLAN COUNCIL OF CANADA 

September 22, 2015 
Ms. Sandy Roberts,
Director Framework for Target Benefit MEPPs
Ontario Ministry of Finance
7 Queen’s Park Crescent 5th Floor, Frost Building South
Toronto ON M7A 1Y7
E-mail:  This email address is being protected from spambots. You need JavaScript enabled to view it. 

 

Dear Ms. Roberts: 

 

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 MEPPs – employers, unions, and professionals. We agree that MEPPs do not fit well into the traditional single employer regulatory model, and support the creation of a MEPP-specific regulatory framework.  Creating such a framework requires intimate knowledge of such plans, and specifically the differences between plans, that can only come from years of hands-on experience.  We therefore strongly recommend that a small group from MEBCO meet with Ministry of Finance (MoF) staff early on for an educational session, so that the MoF staff members involved in this project have a better appreciation of the challenges facing such plans and the similarities and differences among plans that should influence the regulatory framework that is being considered. 

MEBCO is pleased to offer its submission on this core topic for our constituents.  While we will answer the specific questions posed in the Consultation Paper (“CP”), we believe it will be helpful if we start with a summary of some of the major philosophical views of MEBCO with respect to target benefit MEPPs. 

January 29, 2015

 
Hon. Mitzie Hunter
Associate Minister of Finance
Province of Ontario
4117 Lawrence Avenue East
Unit 109
Toronto ON M1E 2S2

 

Re: Ontario Retirement Pension Plan (ORPP) Key Design Questions Consultation

Dear Minister Hunter:

As you are aware, the proposed ORPP will be mandatory for all employers who do not maintain a “comparable pension plan.” A critical question is the definition of a comparable pension plan. MEBCO represents multi‐employer pension plans (MEPPs), many of which include employers and workers in Ontario. The plan sponsor for each of these plans is a board of trustees, often composed of equal numbers appointed by the participating unions and contributing employers. MEBCO strongly supports the Consultation’s inclusion of employers who contribute to target benefit (TB) MEPPs as maintaining a comparable pension plan.

MULTI-EMPLOYER BENEFIT PLAN COUNCIL OF CANADA

September 13, 2015

Ms. Carolyn Rogers, CEO of FICOM

Office of the Superintendent of Pensions

Box 12116

Suite 2800- 555 West Hastings Street

Vancouver, British Columbia V6B 4N6

 

Dear Ms. Rogers:

Re: Definition of “divisional multi-employer plan” under the new BC Pension Benefits Standards Regulation

We are writing on behalf of the Multi-Employer Benefit Plan Council of Canada (MEBCO) members, which include multi-employer pension plans registered in B.C. The purpose of our letter is to identify an issue regarding the definition of “divisional multi-employer plan” under the new BC Pension Benefits Standards Regulation (the new Regulation). Under the new Regulation, a Collectively Bargained Multi-Employer Plan (CBMEP) that is not a Specified Multi-Employer pension Plan (SMEPP) would be classified as a divisional multi-employer plan, which means, among other things, that the assets and liabilities must be tracked by participating employer (potentially a huge administrative burden), and that the participating employers have a claim on the any “excess assets” (which is completely contrary to the principle of a negotiated cost plan, which many CBMEPs will be). Not all CBMEPs are classified as SMEPPs. Unless the Regulations are revised, some multi-employer negotiated cost plans will be required to operate as divisional plans and assume all the additional costs doing so requires.

November 20, 2014

Hon. Charles Sousa                                
Minister of Finance                                   
Province of Ontario                                  
Frost Building South                                
7th Floor                                                
7 Queen's Park Crescent                            
Toronto ON M1E 2S2                       
 
Hon. Mitzie Hunter 
Associate Minister of Finance
Province of Ontario
4117 Lawrence Avenue East
Unit 109
Toronto ON M7A 1Y7

 

Dear Ministers Sousa and Hunter:

Re:    Ontario Retirement Pension Plan (ORPP)

As you are aware, the proposed ORPP will be mandatory for all employers who do not maintain a “comparable pension plan.”  A critical question is the definition of a comparable pension plan.  MEBCO represents multi‐employer pension plans (MEPPs), many of which include employers and workers in Ontario. The plan sponsor for each of these plans is a board of trustees, often composed of equal numbers appointed by the participating and contributing employers. MEBCO strongly urges employers who contribute to MEPPs to be deemed to be maintaining a comparable pension plan.

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.