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.

 

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. 

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.

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.

March 12, 2015

 

Ms. J. Seibel

Lawyer

Legal Branch

Government of Saskatchewan

Financial and Consumer Affairs Authority

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

 

Mr. J. Hall, Senior Crown Counsel

Ministry of Justice and Attorney General

Government of Saskatchewan

Public Law

Legislative Services

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

 

Dear Jan and Jim,

Re: Amendments to Saskatchewan Insurance Act, Bill 177

On behalf of our members, MEBCO appreciates the time you took to meet with our Board member Sid

Matthews, on February 26th. We welcome this opportunity to follow up with you regarding MEBCO’s

comments on Bill 177, which will amend the Insurance Act. We understand that the regulations are not

available and that there are many details to be resolved. We understand the government’s desire to

quickly pass Bill 177 and to consult with relevant parties on the regulations. We also understand, and

agree with, the consumer‐safety focus of the amendments to the Insurance Act.

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.