The Financial Services Commission of Ontario has released guidance for plan administrators on dealing with missing pension plan members.
The policy, which took effect on Sept. 30, doesn’t provide new tools for plan administrators to find former and retired members but it sets out some guidance on how to meet their obligations to update their records and maintain contact. Among other things, the policy suggests regular personalized communication is one of the most effective ways of maintaining contact. While biennial statements are one way of doing that, plan administrators can also consider if more frequent contact is appropriate, the policy statement noted. In addition, it refers to following up on returned mail.
The policy also notes options for searching for missing members. They include contacting union or professional associations, checking internet or social media sites, looking at obituaries and using a private detective. Administrators can also look at broad-based communications on, for example, on a website, in addition to individual searches.
In deciding on which search methods to use, the policy notes the following considerations:
- The nature and location of the employer.
- The pension plan’s size and demographics.
- The magnitude of the pension or commuted-value entitlement.
- The cost of the search.
- The likely effectiveness of the approach.
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Besides laying out some of the options, FSCO issued a separate policy around waivers from sending biennial statements to members believe to be missing. Before submitting a waiver application, administrators must first conduct a search. Each waiver application approved by the superintendent is applicable only to a specific biennial statement and not to those an administrator must send out in the future. If the administrator can’t send a required statement, it must submit a separate waiver application each time but it doesn’t have to conduct another individual search for each missing member covered by a previous approval.
While FSCO’s policy lists the option of using the search services of government agencies to find missing members, it’s worth noting the pension industry has raised concerns about the loss of some services offered by the federal government that previously helped them with the issue.