June 23, Re: Pension Innovation for Canadians: The Target Benefit Plan
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1 June 23, 2014 The Honorable Kevin Sorenson Minister of State Department of Finance 140 O'Connor Street Ottawa, Ontario K1A 0G5 Via E mail: pensions@fin.gc.ca Re: Pension Innovation for Canadians: The Target Benefit Plan The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit comments regarding the Federal government s consultation on a potential target benefit pension plan framework (the Consultation Paper or TBP Framework ). The government's initiative would incorporate TBP provisions into the federal Pensions Benefits Standards Act, and would make TBPs available to federally regulated private sector employers and Crown Corporations. The proposed TBP Framework is a welcome initiative. As background, PMAC represents investment management firms registered to do business in Canada as portfolio managers. Collectively, our member firms manage investment portfolios for most of Canada s pension plans, and as such, have special experience with the issues faced by pension plans, their administrators, advisers and portfolio managers with regard to the investment of pension plan assets. PMAC was established in 1952 and currently represents over 180 investment management firms that manage total assets in excess of $800 billion (excluding mutual fund assets). Our mission is to advocate the highest standards of unbiased portfolio management in the interest of the investors served by Members. Member firms are in the business of managing investments for clients in keeping with each client s needs, objectives and risk tolerances. For more information about PMAC and our mandate, please visit our website at PMAC commends the Government for its commitment to ensuring a secure retirement for Canadians. We are supportive of a TBP Framework and believe the TBP Framework provides a workable alternative to current plan options (defined benefit (DB) and defined contribution (DC) plans) and provides a more long term sustainable option for retirement savings. The flexibility and hybrid nature of the TBP Framework may prove attractive to employers who are moving away from the risks of DB plans. The balanced responsibility of risk between employers and employees is an attractive model as the TBP s shared risk model provides a workable solution to the issues and costs associated with both DC and DB plans. We support the objectives and guiding principles set out in the Consultation Paper and believe that a plan s funding policy and plan s investment policy must be linked to ensure its success. We believe that the Government needs to focus on ways to encourage participation in the TBP Framework and to make the target benefit plan more appealing to employers. One way to do this is to ensure the rules around funding are flexible. We support the proposed conversion feature and believe that for DB plans, there may be an uptick in converting into a TBP. We support the
2 requirement for the consent of all parties to a conversion of existing plans. As we have said in commentary on other pension plan options, the Government also needs to ensure there is sufficient transparency, increased communications with plan members, and adequate governance controls in place to effectively enhance benefit security. If the Government can create an environment in which the TBP is attractive to employers and employees, retirement income security will be improved. Finally, we believe that it would be ideal if jurisdictional differences are minimized across provinces and that there continues to be pension harmonization across Canada. We recommend the government consult broadly to ensure a harmonized regime for TBPs. If you have any questions regarding the comments set out above, please do not hesitate to contact Katie Walmsley at (416) or Julie Cordeiro at (416) Yours truly, PORTFOLIO MANAGEMENT ASSOCIATION OF CANADA Katie Walmsley President, PMAC Scott Mahaffy Chair, Industry, Regulation & Tax Committee Vice President & Senior Counsel MFS Investment Management Canada Limited
3 PORTFOLIO MANAGEMENT ASSOCIATION OF CANADA 2014 MEMBER LISTING Addenda Capital Adroit Investment Management Ltd. Aegon Capital Management Inc. AGF Investments Inc. Aldersley Securities Inc. Alitis Investment Counsel Inc. AMG Canada ATB Investment Management Inc. Aurion Capital Management Inc. Avenue Investment Management Inc. Aviva Investors Canada Inc. Barometer Capital Management Inc. Barrantagh Investment Management Inc. Baskin Financial Services Inc. Beaujolais Private Investment Management Bellwether Investment Management Inc. Beutel, Goodman & Company Ltd. BirchLeaf Investments Inc. BlackRock Asset Management Canada Limited Bloom Investment Counsel, Inc. BMO Asset Management Inc. BMO Harris Investment Management Inc. BNP Paribas Investment Partners Canada Ltd. BNY Mellon Asset Management Canada Ltd. BNY Mellon Wealth Management, Advisory Services, Inc. Brandes Investment Partners & Co. Bridgeport Asset Management Inc. Bull Capital Management Inc. Burgundy Asset Management Ltd. Bush Associates Ltd. C.A. Delaney Capital Management Ltd. Canoe Financial L.P. Canso Investment Counsel Ltd. Cardinal Capital Management, Inc. Celernus Investment Partners Inc. CGOV Asset Management CI Private Counsel LP CIBC Asset Management Inc. Claret Asset Management Corporation Cockfield Porretti Cunningham Investment Counsel Inc. Coerente Capital Management Inc. Coleford Investment Management Ltd. Connor, Clark & Lunn Investment Management Ltd. Cordiant Capital Inc. Coriel Capital Inc. Cougar Global Investments LP Covenant Capital Management Inc. Crestridge Asset Management Inc. Crystal Wealth Management System Ltd. Cypress Capital Management Ltd. Davis-Rea Ltd. De Luca Veale Investment Counsel Inc. Dixon Mitchell Investment Counsel Inc. Doherty & Associates Investment Counsel Dorchester Investment Management Duncan Ross Associates Ltd. Echlin Investment Management Ltd. 18 Asset Management Inc Asset Management L.P. Empire Life Investments Inc. ETF Capital Management Evans Investment Counsel Excel Investment Counsel Inc. Exponent Investment Management Inc. Falcon Asset Management Inc. FI Capital Ltd. Fiera Capital Corporation Focus Asset Management Foster Asset Management Inc. Foyston, Gordon & Payne Inc. Galibier Capital Management Ltd. Galileo Global Equity Advisors Inc. Genova Private Management Inc. Genus Capital Management Inc. GFI Investment Counsel Ltd. GLC Asset Management Group Ltd. Global Wealth Builders Ltd. GlobeInvest Capital Management Inc. Gluskin Sheff + Associates Greystone Managed Investments Inc. Groundlayer Capital Inc. Gryphon Investment Counsel Inc. Guardian Capital LP Heathbridge Capital Management Hélène Dion Investment Management Inc. Hesperian Capital Management Ltd. Heward Investment Management Inc. Highstreet Asset Management Inc. Highview Asset Management Inc. Hillsdale Investment Management Inc. Horizons ETFs Management (Canada) Inc. Howard, Barclay & Associates Ltd. HSBC Global Asset Management (Canada) Limited Pier 21 Asset Management Inc. PIMCO Canada Corp. Portfolio Management Corporation Portland Investment Counsel Inc.
4 Hybridge Investment Management Inc. I.A. Michael Investment Counsel Ltd. IA Clarington Investments Inc. Independent Accountant s Investment Counsel Inc. Integra Capital Ltd. Invesco Canada Ltd. J.C. Hood Investment Counsel Inc. J. Zechner Associates Inc. Jarislowsky, Fraser Limited Jones Collombin Investment Counsel Inc. Kerr Financial Advisors Inc. LDIC Inc. Legg Mason Canada Inc. Leith Wheeler Investment Counsel Ltd. Leon Frazer & Associates Inc. Lester Asset Management Letko Brosseau & Associates Inc. Longview Asset Management Ltd. Lorne Steinberg Wealth Management Inc. Louisbourg Investments Inc. Macdonald, Shymko & Company Ltd. MacDougall Investment Counsel Inc. Mackenzie Investments Manitou Investment Management Ltd. Manulife Asset Management Marquest Asset Management Inc. Martin, Lucas & Seagram Ltd. Mawer Investment Management Ltd. McElvaine Investment Management Ltd. MD Physician Services Inc. MFS Investment Management Canada Limited Milestone Investment Counsel Inc. Mirador Corporation Montrusco Bolton Investments Inc. Morgan Meighen & Associates Limited Morguard Financial Corporation Newport Private Wealth Inc. Nexus Investment Management Inc. Nicola Wealth Management Ltd. Northwood Family Office LP NT Global Advisors, Inc. Pacific Spirit Investment Management Inc. Patient Capital Management Inc. Patrimonica Asset Management Inc. Perennial Asset Management Corp. Picton Mahoney Asset Management QV Investors Inc. Rae & Lipskie Investment Counsel Inc. RBC Phillips, Hager & North Investment Counsel Inc. Rempart Asset Management Inc. Richmond Equity Management Ltd. Ridgewood Capital Asset Management Inc. Rogan Investment Management Ltd. Rondeau Capital Inc. Roundtable Capital Partners Inc. RP Investment Advisors Russell Investments Canada Ltd. Sharp Asset Management Inc. Silver Heights Capital Management Inc. Sionna Investment Managers Sprung Investment Management Inc. Standard Life Investments Inc. Stanton Asset Management Inc. State Street Global Advisors, Ltd. Steadyhand Investment Management Ltd. Strathbridge Asset Management Inc. Stylus Asset Management Inc. Successful Investor Wealth Management Inc. Summerhill Capital Management Inc. Sun Life Global Investments (Canada) Inc. T.E. Investment Counsel Inc. Taylor Asset Management Inc. TD Asset Management Inc. TD Harbour Capital (Division of TD Waterhouse Private Investment Counsel Inc.) TD Waterhouse Private Investment Counsel Inc. Tetrem Capital Management Ltd. Thornmark Asset Management Inc. Toron AMI International Asset Management TriDelta Investment Counsel Tulett, Matthews & Associates UBS Global Asset Management (Canada) Co. University of Toronto Asset Management Vancity Investment Management Ltd. Vantage Point Investment Management Inc. Venable Park Investment Counsel Inc. Vestcap Investment Management Inc. Vision Wealth Management Ltd. W.A. Robinson & Associates Ltd. Watson Di Primio Steel Investment Management Ltd. Watt Carmichael Private Counsel Inc. West Face Capital Inc. Wickham Investment Counsel Inc
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