Multi-Employer Benefit Plan Council of Canada
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. The benefit structures of MEPPs often differ from those of typical single employer plans. Therefore, MEBCO urges you to include MEBCO representatives in the Ministry’s internal and external deliberations so that all employers who contribute to MEPPs can qualify as providing a comparable pension plan on equivalent terms to employers maintaining single employer plans. MEPPs represent a very large number of workers and a very large number of employers with interests that can be significantly different from those of sponsors of single employer plans. A group like MEBCO can speak on behalf of the MEPPs and allow a complete and fulsome consideration of the comparable pension planissue.
Sincerely,
Robert R Blakely,QC
President
cc: LeahMyers
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