According to an article in Benefits Canada, administrative monetary penalties (AMPs) and statements of investment policies and procedures (SIPPs) will be “key concerns for Ontario pension plan sponsors as the provincial government moves forward on major regulatory changes in 2018.” The province’s new administrative monetary penalty regime will come into effect in January. To gain insight into the implications of the changes, author Glenn Kauth turns to pensions and benefits law experts, including Anna Zalewski, counsel in Osler’s Pensions and Benefits Practice Group.
“Breach of [the investment policy statement] is one of the areas for which the new regulator [the Financial Services Regulatory Authority] will be able to impose administrative monetary penalties,” says Anna.
Anna tells Benefits Canada that the changing regulatory environment makes it a good time to take a look at statements of investment policies and procedures. With changes to solvency funding rules in the works in Ontario, plans may want to look at changing their asset mix, which is something they would want to incorporate into the investment document, adds Anna. Key considerations include ensuring the document is accurate and up to date with the changing environment, as well as keeping it flexible enough while avoiding overstating policies in areas such as environmental, social and governance factors, she states.
“I think you might want to think about how your SIPP works as a member communication document,” says Anna, who suggests that while the key aim of the investment document isn’t to communicate with members, the changing regulatory environment makes it more visible. “This is not a legislative requirement,” she clarifies.
For more of Anna’s insight and information on the regulatory changes, read Glenn Kauth’s full article “From AMPs to SIPPs: Why plan sponsors have a lot on the regulatory plate in 2018.”
