Reporting of Late Remittances

The Pension Benefits Standards Act, 1985 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 custodians of these amounts by submitting a contribution planner. This document allows custodians to compare the money that has been remitted into the pension fund with the amounts that were expected.

If a payment into a pension fund is not remitted within 30 days after it was due, the plan administrator and the plan custodian are required to notify the Superintendent. The custodian notifies the Superintendent by sending a non-remittance letter and OSFI follows up with the plan administrator. In many instances where OSFI receives a non-remittance letter, we find that the plan administrator did, in fact, remit the correct amount into the fund. The issue is that they did not update their contribution planner with their custodian, which led to the custodian’s notice to OSFI of non-remittance.

These situations can best be avoided by plan administrators keeping their contribution planners current. When there is a significant change to a pension plan (e.g. a material decrease in plan membership resulting in less money being remitted into the pension fund), then OSFI expects the plan administrator to communicate these changes to their custodian by sending them a revised contribution planner.