Reporting Membership Numbers on the OSFI 49 Annual Information Return

It appears that some plan administrators may be reporting plan membership information incorrectly on the OSFI 49 Annual Information Return (AIR). In particular, "other beneficiaries" may be under-reported and the membership data may not accurately reflect whether plan members working in any given province are subject to federal or provincial pension legislation. This information is important to determine the correct annual assessment for pension plans and to help ensure that the correct pension legislation is applied to members' benefits and entitlements provided by the plan.

As described in the Guide to the OSFI 49 Annual Information Return, "members" and "other beneficiaries" are reported separately. For purposes of the OSFI 49 AIR, other beneficiaries include the following:

• retirees, including retirees for whom an annuity has been purchased by the plan
• survivors entitled to pension benefits under the plan, including survivors for whom an annuity has been purchased by the plan
• former members entitled to a deferred pension benefit under the plan (i.e. deferred vested members), including former members for whom an annuity has been purchased by the plan
• members or survivors who have elected portability under section 26 of the Pension Benefits Standards Act, 1985 (PBSA) but who still have a portion of their pension benefit credit (the transfer deficiency) remaining in the plan
• members or survivors who have elected portability under section 26 of the PBSA but whose pension benefit credit remains in the plan at year end

For purposes of the OSFI 49 AIR, a member of a pension plan is a person who has become a member of the plan and has neither ceased membership in the plan nor retired. The OSFI 49 AIR also asks administrators to report the number of members that are considered inactive. An inactive member of a pension plan is a member who is not accruing benefits and for whom no contributions are being made to the pension plan as at the plan year end. This could include the following:

• members who are temporarily laid-off
• members who are suspended
• members who are disabled or on leave of absence
• members whose accruals have ceased as a result of a benefit "freeze"
• members whose accruals have ceased as a result of a sale of business but whose membership has been deemed not to have ceased in accordance with section 30 of the PBSA

Inactive members do not include retirees and former members entitled to a deferred pension benefit under the plan.

The "grand total" of members and other beneficiaries reported on line 38 (page 20.2012) of a pension plan's OSFI 49 AIR is used to calculate the plan's annual pension assessment. For more information on the calculation of assessments please refer to the Pension Assessments (Fees) page of the OSFI website. Please note that the basic rate for the calculation of plan assessments that are due to be paid between April 1, 2016 and March 31, 2017 is $9.

In accordance with various federal-provincial agreements, OSFI supervises many multi-jurisdictional pension plans on behalf of provinces where the pension plan includes both members who are employed in "included employment" as described in the federal pension legislation and members whose employment is subject to provincial pension legislation. As described in the Guide to the OSFI 49 Annual Information Return, members are to be reported by province of employment and include both provincially and federally employed members. A pension plan's OSFI 49 AIR must also accurately indicate how many members working in any given province fall under federal pension legislation (i.e., work in included employment).