Late Contributions and Communications with Plan Custodians

As mentioned in the article titled “Reporting of Late Remittances” in InfoPensions 9, section 9.1 of the Pension Benefits Standards Act, 1985 (PBSA) states that plan administrators must inform their plan custodians in writing of all amounts to be remitted to the pension fund. Most plan administrators inform their custodian of these amounts by sending the custodian what is often referred to as a “contribution planner.” This document allows the custodian to compare the money that was remitted to the pension fund with the amounts that were expected.

OSFI would like to remind plan administrators that the requirement of section 9.1 of the PBSA applies to both defined contribution and defined benefit plans.

OSFI may contact a plan custodian when following up with a reported late-remittance issue and may also contact a custodian to confirm amounts remitted as part of OSFI’s normal plan monitoring. This might occur if OSFI has identified concerns with respect to the pension plan or if a plan had late remittance issues in the past.