Due diligence required before ending pension payments: OSFI

Before stopping a payment of pension benefits to a retiree or survivor, the Office of the Superintendent of Financial Institutions (OSFI) says plan administrators are expected to obtain sufficient evidence or a reasonable basis to conclude that the retiree or survivor is deceased.

OSFI says some pension plans may be stopping pension benefit payments without performing due diligence.

“A retiree’s or survivor’s failure to complete a form requested by the plan administrator, or respond to a series of letters, should not be considered sufficient evidence or reasonable basis to conclude that the retiree or survivor is deceased,” according to its InfoPensions newsletter.

When attempts to contact the retiree or survivor by phone, mail or email have failed, OSFI recommends the following:

  • send a registered letter to the retiree or survivor;
  • contact the member’s family or in-case-of-emergency contact to obtain written confirmation that the member is deceased;
  • contact the appropriate union to request that they search their records for the retiree’s last known address and contact information;
  • search online white pages;
  • review obituary announcements in local newspapers and/or funeral homes;;
  • contact the financial institution where the pension cheques are deposited or cashed
  • contact the Vital Statistics Records office in each province and territory;
  • contact the National Search Unit with Service Canada;
  • hire a search firm or agency to search public records to assist in finding the retiree(s) and/or survivor(s) or evidence of their death; and
  • if the retiree or survivor is receiving his or her pension benefit by way of direct deposit, if possible, mail a cheque to the retiree or survivor instead.

Those measures, says OSFI, “may aid in establishing sufficient evidence or reasonable basis to conclude that the retiree or survivor is deceased.”