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Responsibilities | Pension Plans
Bulletin 5
New Annual Filing Requirements
October 2006
This bulletin is to inform pension plan administrators, employers, pension consultants, plan members and others about recent changes to the reporting requirements under the British Columbia Pension Benefits Standards Act (the "PBSA").
The investment of pension assets has a significant impact on the pension plan solvency. In view of the growing need to use resources efficiently, and in light of similar regulatory practices in other jurisdictions in Canada and abroad, the Superintendent has expanded the annual reporting requirements by:
- Amending the Annual Information Return (AIR),
- Creating a comprehensive Guide to the Annual Information Return; and
- Introducing a Financial Information Return (FIR) and Guide to the Pension Plan Financial Information Return.
New reporting requirements are in effect for all plan years ending on or
after August 1, 2006. The old reporting requirements will apply for all
plans with year ends of July 31, 2006 or earlier. Audited financial statements
are required to be filed within 270 days of the plan fiscal year end.
The AIR, the FIR and other financial information are required to be filed
within 180 days of the plan fiscal year end.
Changes to the AIR
The most recent changes to the AIR are quite extensive. There are two reasons for this.
- There were certain areas of the AIR which were confusing to plan administrators. The revised AIR, together with the Guide to the Annual Information Return, provides greater clarity.
- The revised AIR has been designed to facilitate electronic filing in the future. We are not ready for electronic filing at present, but we have designed the form in anticipation of electronic filing. We assure administrators who will be unable to file electronically that paper-based copies of our filing requirements will continue to be acceptable.
New Financial Information Return (FIR)
All pension plan administrators must file the new FIR unless:
- the plan is a defined contribution plan, and the total value of plan assets is less than $10 million, or
- the plan is not a defined contribution plan, and assets are valued at less than $2.5 million and there are fewer than 50 members in the plan.
For those plans that are not excluded based on the conditions set out above,
the FIR is supplementary to the financial statements that are required to be filed under
section 9 of the PBSA and must be filed within 180 days after each fiscal year end of the plan
occurring on and after August 1, 2006.
The information included in a pension plan’s FIR will be used in conjunction with the
information in the other filings made on behalf of the pension plan to identify plans
that face increased risk.
The FIR will be a useful tool for identifying irregularities such as significant breaches
of investment regulations, unusual investment under-performance and serious asset-liability mismatch.
The FIR will also allow the Superintendent to be more proactive in identifying plans potentially facing increased investment-related risk.
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Effective immediately, it will no longer be acceptable for the AIR to be
signed by a third party administrator. The AIR must be signed by a
corporate officer of the plan sponsor or a member of the Board of
Trustees |
Additional Filing Requirements for “Multi-Unit” or Divisional Plans
There are a limited number of plans registered in British Columbia that have a
“multi-unit” or divisional structure. Effective with the release of this bulletin, a
separate AIR and FIR must be filed for each unit or division within the plan, for all plan
years ending on and after August 1, 2006.
The filing fees for these types of plans will be based upon the membership of the plan as
a whole, and not the membership in the units or divisions. The maximum fee of $20,000 for an individual
plan will continue to apply.
Information on the new reporting forms and guides may be obtained on our website at http://www.fic.gov.bc.ca/responsibilities/pension/forms/forms.htm.
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