Alberta: Draft guideline on governance, investment and funding policies
On March 28, 2017, the Alberta Treasury Board and Finance (the “regulator”) released a new draft of Interpretive Guideline #12 – Governance, Investment and Funding Policies (“IG-12”). The proposed revision to IG-12 provides more information than the previous draft about the regulator’s expectations for the content of governance, funding and investment policies, as well as the triennial assessment of plan administration. The previous draft was discussed in our July 2015 News and Views.
The revised IG-12 includes the following new guidance:
- A plan administrator can satisfy the obligation to establish a code of conduct and conflict of interest by incorporating references to or extracts from the organization’s code of conduct and conflict of interest policy into the governance policy.
- Plan administrators should consider addressing expenses incurred by trustees (if there are trustees) and how such expenses are reimbursed and disclosed.
- The governance policy should define the skills sets and expertise that third party service providers should possess, including prudence and standards of care.
- The governance policy should define response actions to be taken if decision makers in the governance structure do not acquire required skills in accordance with pre-determined timelines.
- Plan assessments that are required no less than every three years under the Alberta Employment Pension Plans Act may be conducted using Canadian Association of Pension Supervisory Authorities Guideline No. 4: Pension Plan Administrator Governance Self-Assessment Questionnaire, which was most recently updated on December 20, 2016 and discussed in our February 2017 News and Views.
It should be noted that governance policies were already required to be in place for Alberta-registered pension plans by December 31, 2016. The first assessment of plan administration is due by December 31, 2017.
The regulator has requested public comments on the draft revised IG-12 by June 30, 2017.