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.
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
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.
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, 2015Hon. Mitzie HunterAssociate Minister of FinanceProvince of Ontario4117 Lawrence Avenue EastUnit 109Toronto 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
Government of Saskatchewan
Financial and Consumer Affairs Authority
Mr. J. Hall, Senior Crown Counsel
Ministry of Justice and Attorney General
Government of Saskatchewan
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.
- 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.
- 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
- 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.
- 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.
- 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.
- Letter of support of the World Pension Alliance to the MEBCO position on the Target Benefit Legislation for Collectively Bargained Multi-Employer Pension Plans
- Target Benefit Legislation for Collectively Bargained Multi‐Employer Pension Plans (CBMEPPS)
- Save the Date: 9th Transatlantic Conference, Montreal - May 10-12, 2017
- MEBCO Annual General Meeting, Feb
- MEBCO RESPONSE TO SASKATCHEWAN FINANCE AND CONSUMER AFFAIRS AUTHORITY CONSULTATION PAPER: “PROPOSED REGIME FOR NEGOTIATED COST PENSION PLANS”