Consultation Responses

Dec.2, 2024ACPM Comments on the Proposed Amendments to the Pension Benefits Standards Regulations, 1985
Nov. 14, 2024ACPM Submission to Regulations Amending the Pension Benefits Standards Regulations, 1985 Solvency Reserve Accounts and Multi-Employer Pension Plans
Jun. 13, 2022ACPM response to AcSB Exposure Draft - Pension Plan
Jun. 7, 2021
ACPM-Response-to-Bill-C-253 Super Priority of Pensions Provision
Feb. 16, 2021ACPM-letter-to-Finance-re-PBSA
Jan. 14, 2021 
ACPM-Response-Strengthening-Canadians-Retirement-Security
Jan. 6, 2021ACPM-letter-to-MoF-re-Overpayment-Recovery
Oct. 10, 2019ACPM-Response-to-Finance-Canada-re-Tax-changes-and-ALDAs-VPLAs
Jan. 21, 2019ACPM-Submission-Enhancing-Retirement-Security-for-Canadians-Federal-Consultation
Sept. 16, 2016  ACPM-Response-to-Federal-Consultation-30%-Rule
Dec. 15, 2014ACPM Consultation Response Financial Literacy Phase-2
Dec. 8, 2014ACPM-Response-to-the-Draft-Capital-Markets-Stability-Act-(CMSA)-Consultation
Oct. 27, 2014ACPM Submission on Proposed PBSA Regulations
July 15, 2014ACPM-Submission-on-Financial-Literacy-Phase-1-Seniors-(15-07-14)
Jun. 23, 2014ACPM Response to the Department of Finance Canada Target Benefit Plan Consultation Paper
Dec. 8, 2011ACPM Response to Bill C-25 Federal Bill, C-25 (PRPP), First reading (November 2011)
Aug 12, 2011ACPM Response to Dept of Finance Tax Consultation Paper
Mar. 25, 2011ACPM Response to PRPP Working Group Questionnaire 
Apr. 30, 2010ACPM Response to Canada Consultation paper on coverage


Comment Letters

June 2, 2025ACPM and PIAC joint letter on reinstating Canada’s Real Return Bond Program 
May 22, 2025ACPM Letter on PBSA Provisions on Spousal Rights and Electronic Communications
July 5, 2024ACPM Comments on Pension Fund Investment in Canada
Mar.21, 2024ACPM response to Fall 2023 Economic Statement
Nov.13, 2023ACPM submission on Real Return Bonds
July 24, 2023ACPM response to Canada Gazette, Part I, Volume 157, Number 25: Regulations Amending the Pension Benefits Standards Regulations, 1985 (Persons who Cannot be Located)
May 17, 2023Budget Implementation Act, 2023 No. 1 – Division 2 Private Pension Plans
Feb.21, 2023Finance Canada’s Decision to Cease the Issuance of Real Return Bonds (RRBs) – Impact on Pension Benefit Security
Feb.8, 2023ACPM submission to the Senate review of Bill C-228
Nov. 23, 2022OPEN LETTER - Bill C-228, An Act to amend the Bankruptcy and Insolvency Act, (“BIA”) the Companies’ Creditors Arrangement Act (“CCAA”) and the Pension Benefits Standards Act, 1985 (“PBSA”)
Oct.17, 2022ACPM Response to FINA review of Bill C-228, An Act to amend the Bankruptcy and Insolvency Act, the Companies’ Creditors Arrangement Act and the Pension Benefits Standards Act, 1985
Sept 21, 2022
FINA review of Bill C-228, An Act to amend the Bankruptcy and Insolvency Act, the Companies’ Creditors Arrangement Act and the PBSA, 1985
Nov. 3, 2021ACPM-letter-to-Finance-Tax-Borrowing-rules
Feb. 1, 2021
ACPM-Submission-to-Department-of-Finance-re-Borrowing-Rules
Mar. 31, 2020ACPM-Comments-to-Finance-re-COVID19-situation
Mar. 4, 2020ACPM-Letter-re-Pre-retirement-death-waiver-Electronic-communications
May 23, 2019ACPM-Second-Letter-to-Finance-re-PBSA-change-S17-1
May 2, 2019ACPM-Letter-to-Finance-re-PBSA-change-S17-1
Feb. 25, 2019ACPM-Submission-RPP-Annuity-Contracts
Sept.25, 2018Coalition-Letter-Collective-Longevity-Risk-Pooling-Arrangements
Aug. 22 , 2018ACPM-Response-Unclaimed-Pension-Balances-Framework
Apr. 11, 2018ACPM-Letter-to-Finance-re-Bond-Issuance
Mar. 8, 2018ACPM-Finance-Canada-re-Crown-solvency-reductions
Jun. 30, 2017ACPM-Submission-to-AcSB-on-Hybrid-Pension-Plans
May 29, 2017ACPM-Response-to-Regulations-Amending-the-PBSR-1985
Nov. 30, 2016ACPM-Response-Deposit-Insurance-Review
Nov. 28, 2016ACPM-Letter-to-Finance-re-Bill-C-27
Sep. 27, 2016ACPM-Letter-to-Tax-Policy-Branch-Dept-of-Finance
Apr.13, 2016ACPM-Letter-to-Minister-Morneau-re-ORPP-Federally-Regulated-Employers
Sept. 4, 2015ACPM-Consultation-Response-re-Voluntary-Supplement-to-CPP
Aug. 31, 2015ACPM-Letter-re-Multilateral-Agreement-on-PRPPs
Jun. 16, 2014ACPM Comment Letter on Purchased Annuities (Provincial versions of this letter have also been delivered)
Jan. 30, 2014ACPM Letter to Department of Finance Canada re GST/HST Treatment of Financial Services
Mar. 28, 2013ACPM Comment Letter to Minister of National Revenue
Dec. 11, 2012ACPM Comment Letter to Dept. of Finance Canada re.GST/HST
Feb. 14, 2012ACPM Letter to Tax Branch re Revisions to ITA and Regulations
Jan. 25, 2012ACPM FATCA letter to Minister Flaherty
Apr. 7, 2011ACPM Comment Letter on GST/HST on pension plans
Nov. 30, 2010ACPM Comment Letter on GST/HST Rebate for Pension Plans
May 19, 2010ACPM Responds to Proposal for Preferred Creditor Status
Jun. 22, 2009ACPM letter to HRSDC re Proposed Changes to CPP


Pension Review

In January 2009, the federal Minister of Finance issued a Consultation Paper: Strengthening the Legislative and Regulatory Framework for Private Pension Plans Subject to the Pension Benefits Standards Act, 1985".  ACPM participated in the public consultation relating to the Consultation Paper and submitted a response to the Consultation Paper.

ACPM Brief To The Government of Canada on the Consultation Paper Entitled, "Strengthening the Legislative and Regulatory Framework for the Private Pension Plans Subject to the Pension Benefits Standard Act, 1985", March 2009


ACPM President's, Scott Perkin, presentation at the Department of Finance Consultation Hearing on March 20, 2009

COVID-19 AMENDMENTS

Statement of intention from the Department of Finance Canada to recommend an amendment to the Income Tax Regulations (the Regulations) to facilitate the administration of registered pension plans (RPPs) during the COVID-19 pandemic.


Waiver of 1% minimum employer contributions on the Registered Plans Directorate
https://www.canada.ca/en/revenue-agency/services/tax/registered-plans-administrators/whats-new.html

Statement of intention from the Department of Finance Canada to recommend an amendment to the Income Tax Regulations (the Regulations) to facilitate the administration of registered pension plans (RPPs) during the COVID-19 pandemic. Read the letter HERE.