On July 15, 2015, Finance Canada released a draft multi-lateral
agreement respecting pooled registered pension plans
("Proposed Agreement") for public comments in a 45-day
period. The Proposed Agreement was also published in the July 15,
2015 Gazette officielle du Québec (Part 2) for comments
during the same period. The expressed purpose of the Proposed
Agreement is to streamline the administration of pooled registered
pension plans ("PRPPs"), resulting in reduced costs and
greater access to PRPPs as a new private pension option. The
Proposed Agreement does not have any impact until finalized and
signed. Once the Proposed Agreement is signed and implemented, it
affects federal and provincial PRPPs and, to a certain extent,
Québec voluntary retirement savings plans
Below are certain key features of the Proposed Agreement.
A province is bound by the Proposed Agreement only if it signs
the Proposed Agreement. At this stage, the Proposed Agreement
contemplates that it will be signed by Alberta, British Columbia,
Nova Scotia, Saskatchewan and Quebec. The usefulness of the
Proposed Agreement depends on federal and provincial buy-in.
Certain licensing exemptions are available for a holder of a
VRSP administrator licence (in which case, a licence to act as a
federal or provincial PRPP administrator is not required) or a
holder of a federal PRPP administrator licence (in which case, a
provincial PRPP administrator licence is not required but a VRSP
administrator licence is required with much simpler requirements).
A holder of a provincial PRPP administrator licence is not exempted
from obtaining a federal PRPP or a VRSP administrator licence.
A federally-registered PRPP text can be used as a provincial
PRPP but not as a VRSP unless it is also registered with the
Régie des rentes du Québec
("Régie"). A provincially registered PRPP text
cannot be used as a federal PRPP or a VRSP without registration
with the federal regulator or the Régie, as the case may be.
The supervisory authority of a provincial PRPP which is also
registered as a federal PRPP is delegated to the federal regulator.
The federal PRPP legislation applies to a federally-registered PRPP
which is also used as a provincial PRPP except for specified
matters (e.g., spousal rights, withdrawals, payments and transfers
from a PRPP).
The Proposed Agreement also contains a mechanism for the
subsequent addition of provincial parties and notice provisions
regarding withdrawal and termination.
Our Pension and Benefits Group will monitor the progress of the
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