Incomplete Member Statements

OSFI’s on-site examinations of pension plans continue to find that some member statements (i.e. personalized annual statements and statements on death, termination and retirement):

• do not contain all the information required by the Pension Benefits Standards Regulations, 1985 (PBSR) or
• do not accurately reflect the provisions of the plan documents.  

For example, where a plan provides a benefit (such as subsidized early retirement) that is subject to the consent of the plan administrator, some member statements fail to indicate that receipt of this benefit is subject to the consent of the plan administrator. 

Member statements should clearly outline the members’ rights and benefits provided under the terms of the plan.  Incorrect disclosure to plan members may result in potential claims for increased benefits based on the assertion that they were not provided with appropriate, timely and adequate information. 

When OSFI assesses a plan’s risks regarding their communication to members, incorrect member statements may increase the plan’s assessed level of legal and regulatory risk (please refer to OSFI’s Risk Assessment Framework, specifically the Guidance Note on Communication to Members).  Plan administrators should have the appropriate measures and controls in place to ensure communication to members complies with the Pension Benefits Standards Act, 1985, PBSR and the plan documents.