The Association of Canadian Pension Management is asking the Canadian Association of Pension Supervisory Authorities to allow for some flexibility in its revised guidelines on pension plan governance, saying the principles laid out could be intimidating and onerous for smaller pension plans.

“Good governance will look different from plan to plan,” wrote Bryan Hocking, chief executive officer of the ACPM, adding that more clarity is need around the following statement in the consultation document: “Different types and sizes of plans, however, may require different governance practices.”

The CAPSA guideline No. 4 draft consultation was published in March, asking pension industry stakeholders for their comments and feedback. It is part of CAPSA’s strategic initiative to review and determine if revisions are necessary to its pension plan governance guidance.

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In its letter to CAPSA, the ACPM also asked for clarification on how the guidance defines multi-employer pension plans in its frequently asked questions section. “The questions seem to assume that MEPPs are defined benefit only,” wrote Hocking. “Would it be beneficial to address the investment of the assets of the plan also in terms of providing appropriate investment choices to members of a defined contribution MEPP?”

And, finally, the ACPM also pointed out that CAPSA’s guideline No. 6 on pension plan prudent investment practices and its accompanying self-assessment questionnaire, which were issued in November 2011, is due for a review as well.

“We encourage CAPSA to continue to revisit these governance guidelines going forward,” wrote Bryan Hocking, chief executive officer of the ACPM. “New developments in the retirement income system in Canada could require revisions in the future.”

Read: DC governance ‘doesn’t have to be onerous,’ says plan sponsor

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