Why is electronic filing required?
OSFI has introduced electronic filing for pension plans to reduce data errors and improve data integrity. OSFI supervises over 1,300 pension plans and receives returns (AIRs and CFSs) annually from each of these plans. We also have a Memorandum of Understanding with the Canada Revenue Agency (CRA) whereby we collect information on CRA’s behalf. OSFI relies on these returns to allow us to carry out our risk-based supervisory approach for pension plans. To date, all pension plan returns submitted to OSFI have been in paper format.
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When is electronic filing required?
For all plan year-ends after October 1, 2006, pension plans must file their annual returns electronically. Plans must still file their annual returns by the usual dates (June 30 for most plans).
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How do I file my returns electronically?
- Go to the Pension Plans Diskette Filing area of the OSFI Web site under / list of diskette filing software vendors.
- Choose a vendor and sign up to use their software.
- Follow the vendor instructions in filling out the forms electronically and in putting together the complete package to be sent to OSFI.
- The complete package should include the following:
- correctly labelled diskette or CD,
- Diskette Transmittal Form for each return. The Diskette Transmittal Form provides certification that the filed diskette or CD was generated using software that has been tested, approved and produced in accordance with OSFI specifications.
- Certification Forms for each return (AIR and CFS). An authorized officer of the plan administrator must sign the Certification Forms. The plan administrator is certifying that information provided is true, correct and complete. This certification applies to both the OSFI and CRA information.
Error Handling : It is important that all data be free of errors before the diskette/CD is filed; otherwise the diskette/CD will be returned for correction and the filing requirement will not be considered to be met until an error-free diskette/CD is received.
Note : The diskette filing of the CFS does not affect the filing requirements for an Auditor’s Report. Pension plans that are required to file an Auditor’s Report must continue to do so (see the Guide to the Certified Financial Statements on our Pensions web site).
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What does it cost?
OSFI did not set the pricing for the electronic filing software, so it is up to each pension plan administrator to check vendors’ prices. Prices may vary depending on the size of the plan, both in terms of assets and membership.
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Why CDs or diskettes – why can’t the returns be e-mailed to OSFI?
Some of the information provided is of a sensitive nature, and according to government policy, cannot be sent by unsecured means. OSFI also requires physical signatures on the certifications that go along with the electronically filed returns.
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Why only the AIR and CFS – what about the other returns that must be filed with OSFI?
Over time, OSFI intends to make all of our returns electronic. The AIR and CFS are the first step. They are also the highest volume returns received by OSFI. Most other forms are generally ad-hoc or specific to a smaller group of pension plans.
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Who do I call if I have a question?
Any questions should be addressed to Bruce Martin, Regulatory Information Division at (613) 990-8160 or Bruce.Martin@osfi-bsif.gc.ca.
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Are there any exceptions?
If your plan is a new plan (i.e. no OSFI registration number yet), then you will have to file paper returns. Please contact Bruce Martin (613) 990-8160 if this is the case.
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Why do we have to pay for the software? Why is it not free?
OSFI's operational costs are charged back to the industries it regulates. As a result, any charges that OSFI would assume by providing this software would ultimately be assessed back to the pension plans through their annual fee or a direct charge. OSFI chose to let plan administrators source their own software as, in our view, this allows for innovation and competition amongst suppliers which will benefit plan administrators in the long run.
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