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MEBCO Alberta PfAD Meeting October 6, 2023

To Whom it May Concern: 

On behalf of MEBCO – We would like to express our appreciation for your time on October 6, 2023, to hear our concerns regarding the Provision for Adverse Deviation (PfAD) funding requirements in Alberta’s regulations for multi-employer pension plans. To summarize:

1. the Alberta PfAD is flawed – everyone in the province including the regulator and legislator has acknowledged that.
2. Alberta has lost pace with the rest of the country on repairing flawed pension rules – British Columbia, Saskatchewan, Ontario, and the federal government have either changed their PfAD or will do so shortly – Alberta must catch up for its 200,000+ members.
3. it can be fixed easily through an Order in Council – a legislative change is not required – Premier Smith advised us this fix was “low hanging fruit” suggesting that the matter is easy to resolve.4. there is precedent for correcting legislation in the multi-employer pension plan sector – the last time was in 2017 for commuted values which were corrected by an Order in Council.
4. multi-employer pension plans have solid governance structures and with a minimum of 7.5% PfAD will continue to be well-funded and sustainable; and
5. tens of thousands of plan members, including retirees living on a fixed income, would benefit immediately from our requested change through an Order in Council.

MEBCO would be happy to meet with you again as we continue forward in our effort to have the regulations surrounding multi-employer PfAD funding requirements improved through an Order in Council.

About MEBCO 

The Multi-Employer Benefit Plan Council of Canada (MEBCO) was established in 1992 to represent the interests of Canadian multi-employer pension and benefit plans (MEPs). MEBCO consults 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, and 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 pension and health coverage to over 1,000,000 Canadians. 

Yours truly,

Alex D. McKinnon, President 

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