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Ontario: new Form 14 to file with Statement of Investment Policies

The Financial Services Commission of Ontario (FSCO) has released Form 14 – Statement of Investment Policies and Procedures (SIPP) Information Summary.  Plan administrators are required to file Form 14 with FSCO for each Ontario-registered pension plan when filing the plan’s statement of investment policies and procedures (SIPP). As a reminder, the requirement to file a plan’s SIPP with FSCO is effective January 1, 2016. To assist plan administrators with completing and filing Form 14, FSCO has also released a User Guide.

What is the purpose of Form 14?

Form 14 is intended to provide FSCO with general information regarding the plan’s SIPP, along with confirmation that the SIPP complies with the requirements of the Ontario Pension Benefits Act (PBA). Form 14 also requires the administrator to confirm a SIPP’s compliance with the new PBA requirement regarding Environmental, Social & Governance (ESG) factors.

When is an administrator required to file Form 14 with FSCO?

Form 14 must be filed at the same time the SIPP or a SIPP amendment is filed with FSCO. As a reminder, a SIPP is required to be filed by March 1, 2016. A SIPP amendment must be filed within 60 days after the amendment is made.

How does an administrator file Form 14 (and the SIPP)?

Beginning in January 2016, Form 14 can be accessed and completed on FSCO’s Pension Services Portal (PSP). Both a completed and certified Form 14 and the SIPP (in PDF searchable format) must be uploaded through the PSP.

What is the content of Form 14?

Form 14 has six parts, and is designed to accommodate different types of pension plans (including combination and hybrid plans). Depending on the type of plan, the form lists the matters that must be addressed in a SIPP, as required by the regulations. Some of the information in Form 14 will be auto-populated according to FSCO’s current records for the plan (e.g., plan name, administrator and employer name, etc.).

What happens if the administrator discovers that the SIPP is not compliant when completing Form 14?

Form 14 requires the administrator or the administrator’s representative to certify compliance with the legislative requirements (e.g., failure to address whether ESG factors are considered). If the SIPP is not compliant, it cannot be filed with FSCO until it is amended to be properly compliant.

Conclusion

Form 14 is detailed, and requires administrators to closely examine whether a plan’s SIPP is compliant with the PBA and regulations. It is therefore important that administrators not leave completion of Form 14 to the last minute, especially if it is discovered that a plan’s SIPP is not compliant and must be amended before it can be filed with FSCO.

Since there are parts of the Form 14 that are automatically populated based on FSCO’s records, it is important that administrators keep their contact and plan information up-to-date on the PSP.