Multi-Employer Benefit Plan Council of Canada
We wanted to thank FSRA for their continued collaboration with the Multi-Employer Benefit Plan Council of Canada (MEBCO) on the updates to the Target Benefits Guidance. We have reviewed the Summary of Questions from April/May 2025 TAC Conversations document shared with stakeholders along with the revised version of the Guidance incorporating areas of initial feedback.
Although many of our suggestions have been considered, we would like to address again the section on Notice Requirements located under the "Notice" heading in the Summary of Questions document. It includes questions 15 and 16, addressing member notice requirements and the interpretation of eligibility requirements in the Appendix.
The question was related to multiple member notice requirements related to the conversion process each with potentially different timing obligations. We believe that consolidating these notice requirements to a single notice to members and participating employers will foster less confusion and limit expenses for plans. Although our comment is not incorporated in the revised Guidance, we were pleased to see s that FSRA may consider on a case-by-case basis whether the legislative and regulatory requirements are met using a single notice.
We continue to appreciate FSRA’s collaborative efforts. We appreciate this opportunity to contribute.
Thank you.
Alex McKinnon
President, MEBCO
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