In the context of the COVID-19 outbreak, we have implemented 2 temporary easing measures to assist administrators of supplemental pension plans. Once parliamentary proceedings resume, the measures may be subject to specific legislative provisions.
The measures covering supplemental pension plans are:
- the extension of deadlines for certain regulatory and legal obligations
- an update to the degree of solvency that must be taken into account for payments (transfers and refunds) under defined benefit pension plans.
General extension of 3-month deadlines
We have extended the deadlines for providing certain documents to Retraite Québec and to members by 3 months, without penalty (additional fees). For more information, see the table below.
Please note that the extension applies to all the deadlines that had not expired by 12 March 2020, but which would have expired in 2020.
Impacts on a plan whose fiscal year ended on 31 December 2019
|
Supplemental pension plan (SPP) |
Current deadline |
Extended deadline |
|---|
| Annual statement for members and beneficiaries | 30 September 2020 | 31 December 2020 |
| Triennial or annual actuarial valuation, actuarial valuation for an amendment to the plan or for the use of excess assets | 30 September 2020 | 31 December 2020 |
| Actuarial valuation for a purchase of annuities | Within 4 months of the date of purchase | Current deadline + 3 months |
| Actuarial valuation required by Retraite Québec | Within 60 days of the date of the valuation | Current deadline + 3 months |
| Notice regarding the plan's financial situation | 30 September 2020 | 31 December 2020 |
| Actuarial valuation for a negotiated contribution plan | 30 June 2020 | 30 September 2020 |
| Recovery plan for negotiated contribution plans | Within 18 months of the valuation date | Current deadline + 3 months |
| Application for registration of amendments provided for in the recovery plan | Within 24 months of the valuation date | Current deadline + 3 months |
| Annual information return (AIR) and financial report | 30 June 2020 | 30 September 2020 |
| Notice of annual meeting | 30 September 2020 | 31 December 2020 |
| Termination report | Within 90 days of receiving the termination report | Current deadline + 3 months |
| Termination or employer withdrawal report (if the employer is insolvent) | Within 120 days of the date of the termination or withdrawal | Current deadline + 3 months |
|
Supplemental pension plan (SPP) |
Current deadline |
Extended deadline |
|---|
|
AIR and financial report | 30 June 2020 | 30 September 2020 |
IMPORTANT: The following deadlines have not been extended:
- deadline for sending a statement once an employee leaves;
- deadline for filing a transfer application.
Update to the degree of solvency that must be taken into account for payment (transfers and refunds) under defined benefit pension plans
All payments (transfers and refunds) between 17 April 2020 and 31 December 2020 must take into account a degree of solvency that reflects the plans' current financial situation.
Therefore, the payments must take into account the degree of solvency updated on the last working day of the month preceding the date on which the value of the member's benefits was determined. However, if the date on which the value is determined is prior to 1 April 2020, the degree of solvency must be determined based on the plan's estimated financial situation as at 31 March 2020.
The degree of solvency must be the one estimated by an actuary based on the plan's estimated financial situation, by taking into account, in particular, the real rate of return of the pension fund, changes in interest rates on a solvency basis and contributions that were made since the plan's last complete actuarial valuation. It is not necessary to provide the estimate unless Retraite Québec requests it.
Additional information concerning actuarial valuations as at 31 December 2019
The
Supplemental Pension Plans Act provides for the funding of a pension plan to be based on an actuarial valuation that must be produced at least every 3 years. As a result, a plan could choose to produce an actuarial valuation as at 31 December 2019, regardless of whether it is required. The measure is already allowed under the Act and does not require any authorization from Retraite Québec.
Payment of contributions into the pension fund
Despite the current situation, deadlines for making payments into the pension fund (every month) and for notifying Retraite Québec of any unpaid contribution (within 60 days after it becomes due) have not been extended.
Additional information
For all questions regarding the administration of your retirement pension, contact the Direction des régimes complémentaires de retraite
by telephone or by email at
rcr@retraitequebec.gouv.qc.ca.