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.

May 23, 2017 – TORONTO, CANADA - From May 10 to May 12 MEBCO (Multi-Employer Benefit Council of Canada) hosted the 9th annual transatlantic conference. Partners in the conference, held in Montreal, were the European Association for Paritarian Institutions of Social Protection (AEIP) and the United States’ National Coordinating Committee for Multiemployer Plans (NCCMP). Topics discussed included global trends in regulation and supervision of pension plans, environmental social and governance issues for pension plan investments. Health topics included emerging trends and innovation in health care. Panels of global experts discussed best practices foe disease prevention and workplace health and safety. The conference closed with a discussion on the social dialogue and the state of play in Canada, the US and globally.

Phylis C. Borzi and Bob Baldwin Keynote Speakers at 9th annual World Pension Alliance conference – Montreal

Bob Baldwin, an Ottawa-based expert in global pension governance provided a keynote address to the 9 th annual transatlantic conference in Montreal. Bob’s address covered the evolution of pension coverage that covered global trends. He discussed the pillars in the retirement system and encouraged thought on pension adequacy. The Honorable Phylis C. Borzi, former US Assistant Secretary of Labor for the Employee Benefits Security Administration (EBSA) discussed trends in pension regulation and supervision. The panel discussed the complex regulatory environments in Canada, the US and Europe. Papers delivered by conference speakers can be found at mebco.org.

Expert Panel review of global pension systems

A panel that included Yvonne Yee Mun Sin, ASA, ACIA, MAAA recently head of global pensions at the World Bank, Gerhard Rieman, Director, Pensionfederatie, The Netherlands and Randy Defrehn of the National Coordinating Committee for Multiemployer Pension Plans (NCCMP) discussed the evolution of risk sharing with citizens through defined contribution pension plans. The panel discussed the need to have intersectorial (financial, health, labour, social) cooperation to manage pension plans on a holistic basis. The panel also agreed with the premise that pensions need multi-disciplinary champions that advocate for pensions. The committee also heard about concerns in both the US and Canada regarding transfers out of commuted values that can create problems due to financial literacy constraints. Papers delivered at the conference can be found at mebco.org.

Distinguished Panel discusses ESG issues at 9th Transatlantic Conference

Liam Kennedy, Editor of Investment Pension Europe led a panel discussion that covered important issues relating to ESG in the selection and management of pension fund investments. Panel member Mike Mazzuca of Koskie Minsky LLP discussed fiduciary issue in employment of ESG principles. Judith Moore, Head of Sustainability Research and Policy at Affirmative Investment Management discussed the evolution of green bonds. Papers delivered at the conference can be found at mebco.org.

The Honorable Earl Pomeroy – 9th Transatlantic Conference Keynote Speaker on US Health Care

The Honorable Earl Pomeroy, a former US government congress member representing North Dakota provided the 9th annual transatlantic conference with an historical view of the US health care system that includes Medicare, Medicaid, private coverage and employer-provided coverage. He highlighted that 49% of Americans’ have health care through employer-sponsored plans and another 22% of Americans are covered by Medicare and Medicaid. He estimated that 24 million Americans will have less or no health care under the proposed changes to Obamacare (the Affordable Care Act). Papers delivered at the conference can be found at mebco.org.

Jean-Louis Peyrude discusses “Nudging” at 9th Transatlantic Conference

In his address to the 9th annual transatlantic conference Mr. Peyrude, President of OCIRP – organisme commun des instituions de ren et de preyvoyance) the union of French provident institutions discussed best practices for disease prevention. He highlighted the importance of “nudging” – encouraging small changes in behavior that can have positive health results.

9th transatlantic conference panel on prevention strategies for psychosocial risks and mental health promotion

An expert panel in workplace mental health that included Jeane Day, Director General, groupe enterprises et sante, Canada, Dr. Marie-Helene Pelletier, Assistant Vice President Sun Life Financial, Clement Allanic, PSYA, France, Joseph Riccuitti Co-founder of Mental Health International and Stephen O’Sick of the Bricklayers Union Local 2 led an informed discussion on the tools available to employers, employees and unions for education about mental health. Ms. Day reviewed the training tools available to Quebec employers including multi-level certification in mental health training. Dr. Pelletier illustrated the link between financial wellness and mental health. Mr. Allanic reviewed the services provided by PSYA France and shared recent statistics from French employer groups. Mr. Riccuiti provided an overview of mental health issues in Canada and challenged the conference attendees to explore workplace issues more deeply. In particular he encouraged thinking about how mental health issues do impact the workplace whether or not the issue is founded in the workplace. Mr. O’Sick informed about his union’s experiences with drug addiction and especially the misuse of opiods. Papers delivered on this topic can be found at mebco.org.

World Pension Alliance elects new Chair

At its plenary meeting, voting members of the World Pension Alliance (WPA) that includes the American Benefits Council, Association of Superannuation Funds of Australia, European Association of Paritarian Institutions of Social Protection (AEIP), International Federation of Pension Funds Administrators (FIAP), Multi Employer Benefit Council of Canada (MEBCO), National Conference on Public Employees Retirement Systems (NCPERS), National Coordinating Committee for Multiemployer Pension Plans (NCCMP) and PensionsEurope elected Susan Bird, representing MEBCO as its Chair for 2017/2018. Susan succeeds Bruno Gabbellieri of AEIP who chaired the WPA from May 2016. WPA’s Vice Chair for 2017/2018 is Matti Leppalai of PensionsEurope. The WPA’s coordinator for 2017/2018 will be Dr. Francesco Briganti. The WPA estimates its members provide pension benefits to 350 million individuals and assets of USD 7 trillion. The WPA is headquartered in Brussels, Belgium. 

Papers can be found at www.mebco.org. For more information contact This email address is being protected from spambots. You need JavaScript enabled to view it..

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)

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.

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.

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.