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In our most recent post, we highlighted some of the regulatory relief available to administrators of Ontario registered pension plans as a result of COVID-19. In this post, we highlight the various forms of relief that have been made available, to date, by the pension standards regulators in jurisdictions other than Ontario.
On March 30th, the British Columbia Financial Services Authority (“BCFSA”) published Pension Bulletin 20-002, COVID-19: Relief Measures for Pension Plans in British Columbia, in which it announced the following measures for pension plans registered in British Columbia:
- Extension of the deadline to provide annual statements to active members and persons receiving pensions by 60 days for all plans required to provide such statements between March 30, 2020 and December 29, 2020.
- For collectively bargained multi-employer plans, extension of the deadline to prepare termination of active membership statements for plans with a March 30, 2020 deadline, by 30 days. For all other plans, the prescribed timelines for preparation of such statements has not been extended but plan administrators may apply to BCFSA for an extension.
- Extension of the due date for all plans required to file annual information returns and financial statements between March 30, 2020 and December 29, 2020 by 60 days.
- Extension of the deadline for the filing of actuarial valuation reports and actuarial information summaries by 90 days for reports with a review date of December 31, 2019 and / or a due date in 2020.
On April 1st, the Alberta Superintendent of Pensions released EPPA Update 20-01, COVID-19 Relief Measures(“Alberta Update”), pursuant to which the Alberta Superintendent immediately provided certain administrative relief to all pension plans registered under the Employment Pension Plans Act (Alberta), including the following measures:
- Extension of the deadline for the filing of annual information returns and associated annual fees, audited financial statements and/or actuarial valuation reports and cost certificates that are due to be filed between March 31 and prior to July 1, 2020 by 180 days.
- Extension of the deadline to issue annual statements to active or retired members that are due to be issued between March 31 and prior to July 1, 2020 by an additional 180 days.
- Extension of the deadline to issue a plan summary or member-driven event disclosure statement (e.g., termination statement) that is due to be issued between March 31 and prior to July 1, 2020 by an additional 90 days.
In the Alberta Update, it is also recommended that extensions to the amortization periods for unfunded liabilities and / or solvency deficiencies as well as the deadline for the remittance of employer and employee contributions be discussed on a case-by-case basis with the Superintendent.
On April 2, 2020, the Saskatchewan Financial and Consumer Affairs Authority announced the following extensions for certain filing and disclosure deadlines for pension plans registered under The Pension Benefits Act, 1992 (Saskatchewan):
- Extension of the due date for all plans required to file their annual information return between March 31 and July 31, 2020 by 3 months.
- Extension of the deadline to provide annual statements to members by 3 months for all plans required to provide members with annual statements between March 31 and July 31, 2020.
On April 1, 2020, the Nova Scotia Finance and Treasury Board announced that the deadline for filing annual information returns and actuarial valuation reports due on either March 31 or April 31 has been extended until May 31, 2020.
Effective March 27, 2020, the Office of the Superintendent of Financial Institutions (“OSFI”) announced a full freeze on portability transfers and annuity purchases related to defined benefit provisions of pension plans. During the freeze period, plan administrators may request consent to a transfer or annuity purchase based on plan specific or special circumstances.
At the same time, OSFI also announced a number of filing deadline extensions, including the following measures:
- Extension of the deadline for filing annual information returns, certified financial statements and actuarial reports and actuarial information summaries by 3 months.
- Extension of the deadline for issuing annual statements to members and former members and spouses or common-partners by 3 months, although it is recommended that administrators notify recipients of the expected delay.
It is expected that additional relief will be announced by other pension standards regulators in the coming days. For further information or to discuss your obligations as a plan administrator, please contact Kim Ozubko at firstname.lastname@example.org or (416-597-4338), and subscribe to our A.M. Pension Blog series to stay informed on the latest developments.
Miller Thomson is closely monitoring the COVID-19 situation to ensure that we provide our clients with appropriate support in this rapidly changing environment. For articles, information updates and firm developments, please visit our COVID-19 Resources page.