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© Copyright 2002
Rogers Media. The following article first appeared in the March 2002 edition of
BENEFITS CANADA magazine.
Best practices
Legislation could stall the growth of DC plans.
Any changes should be limited to defining stakeholders' roles and developing a
best-practices model.
BY BILL KYLE
Last spring the Joint Forum of Financial Market
Regulators released an important discussion paper, Proposed Regulatory
Principles for Capital Accumulation Plans. The proposals could significantly
impact the DC market, and it is important for the industry to ensure that any
reforms do not impair the growth and benefits associated with these plans.
Regulations introduced in the early 1990s
contributed to a noticeable decrease in the number of employers offering pension
plans in Canada. For example, in Ontario the number of registered plans dropped
from more than 10,000 to approximately 6,000. During this same period, group
registered retirement savings plans (RRSPs) took off across Canada. Plan
sponsors embraced them as a means of avoiding regulatory constraints. According
to the Canadian Life and Health Insurance Agency, between 1985 and 2000 group
RRSPs grew from 7,500 plans and $1.6 billion in assets to 20,000 plans and
assets of $15 billion.
The objective of new regulations should be limited to creating an environment
in which retirement plans thrive and provide more Canadians with valuable
retirement benefits. The benefits of group plans include: wholesale investment
management fees that provide, on average, 20% more retirement income than the
same investment in an individual retirement plan; employer contributions;
dollar-cost averaging; and convenient payroll deductions.
Keeping this in mind, regulatory proposals should focus on two goals. The
first is to clarifiy the role that key stakeholders play in a DC plan. These
parties consist of members, sponsors, advisers and suppliers. The most important
role is the plan member. After all, employees decide how much money to set aside
for retirement and, in most cases, make their own investment selections.
The plan sponsor is next in the hierarchy. Employers manage retirement
programs that serve the interests of plan members, helping them to make suitable
fund selections and establish an adequate contribution level. The sponsor's
adviser and supplier take on the other two important roles. Clarifying all these
roles will allow all the parties to work together and manage a successful plan.
SETTING THE STANDARD The second goal of
regulatory change should be to set a common standard for all plans, regardless
of the provider. A level playing field for all providers ensures that the needs
of the member will be met, regardless of who administers the plan. A common
standard should be developed on a best-practices model and include: affordable
and appealing plan designs; access to wholesale investments; an
employer/provider role in selecting and monitoring appropriate managers and
funds; a disciplined planning and investment selection process; employee
education; and diverse service and product features.
There are a number of reasons for not proceeding with any legislative reform
in the DC sector. First, providers and employers will have to deal with
numerous, conflicting standards as each province establishes its own rules.
Another drawback is the fact that regulations will not allow for flexibility
under special circumstances. They will also be quickly dated due to the ongoing
changes in the group retirement market.
Most worrisome, if applied to all DC plans, new regulations may result in
more red tape. Employers may simply offer cash compensation instead of setting
up a group retirement plan.
If reforms are indeed required, regulators should limit them to clarifying
the role of stakeholders, publishing a best-practices guide and providing a safe
harbour for plan sponsors that demonstrates compliance with best practices. This
way regulations for the DC market will not impede its growth but help to
increase retirement benefits for working Canadians. This is to everyone's
advantage. BC
Bill Kyle is
vice-president, group retirement services, with Great-West * London Life in
London, Ont. bill.kyle@londonlife.com.
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