NEWS & VIEWS. Alberta Introduces New Pension Act. 2 New Ontario Regulations Provide Anticipated Funding Flexibility

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1 NEWS & VIEWS IN THIS ISSUE 1 Alberta Introduces New Pension Act 2 New Ontario Regulations Provide Anticipated Funding Flexibility 3 Proposed Mortality Table and Improvement Scale Will Increase Canadian Pension Liabilities 4 Buying Annuities for Defined Benefit Plans: Why Not? 5 Group Benefit Changes Effective January 1, Who Determines the Assumptions for Pension Plans? 8 Market Indices 9 Tracking the Funded Status of Pension Plans 10 Impact on Pension Expense under International Accounting 11 About Us Alberta Introduces New Pension Act The Alberta government has introduced Bill 10, the Employment Pension Plans Act, to replace its current pension legislation. Bill 10 closely follows British Columbia s Bill 38, which was passed in June. Please see our News & Views article from May 2012, as all of the key changes discussed in the article will also apply in Alberta. The Alberta Ministry of Treasury Board and Finance summarizes the key features of the new legislation as follows: zharmonized pension rules between Alberta and British Columbia, making it easier for pension plans to both start up and operate effectively for their members. zmore flexibility in pension standards, making it easier for private sector employers to design pension plans that meet both their needs and the needs of their employees. zextended timelines for dealing with funding shortfalls. zmore clarity around the roles and responsibilities of those involved in managing pension plans. zstandards for two new types of plans: target benefit plans and jointly sponsored plans. ztarget benefit plans provide a specific pension amount when a member retires, similar to a defined benefit plan. The benefit amount may be reduced if funding difficulties arise, lowering employer funding risk. To ensure plan members can have reasonable confidence that their promised benefit will be delivered, specific funding rules for these plans will be put into place Morneau Shepell November 2012 Volume 9, issue 11 1 of 11

2 zjointly sponsored plans see members share in the total cost of the plan with the employer, as opposed to contributing only towards their own benefit. zincreased focus on disclosure, helping all parties understand the terms, risks and health of their plan, as well as their responsibilities around the plan. zqualification for vesting, which is the entitlement of a member to the benefit promised under their pension plan, has been changed from two years of plan membership to immediate, recognizing that pension benefits are a part of an employee s compensation, rather than a reward for long service. zlocking in will no longer be based on years of service, but on a minimum dollar amount that is increased annually. This will eliminate the locking in of amounts that are too small to provide a meaningful pension, and means that locking in rules will keep pace with inflation. The final bullet refers to the fact that both vesting and locking in will be immediate, but the small benefits unlocking rule may be expanded. The full details of the new unlocking threshold will be specified in the regulations. Of particular note is the point regarding extended timelines for dealing with funding shortfalls. While B.C. and Alberta are making efforts to harmonize their legislation, the one area where the two provinces have differed materially in recent years is in regard to solvency relief, particularly with respect to single employer plans. The reference point on this topic in Alberta s summary did not appear in the summary that accompanied B.C. s new legislation. We understand that the two provinces are undertaking consultations with stakeholders regarding funding issues, but it remains to be seen whether the new rules in either province will provide permanent relief measures or if the two provinces can agree on one consistent approach. Further, as noted in our May issue, the treatment of small designated plans (many of which are individual pension plans) is still somewhat up in the air. Historically, Alberta and B.C. have treated this category of plans quite differently. Our consultations lead us to believe that B.C. is moving to an environment more closely resembling Alberta s, with increased regulatory requirements facing sponsors of these plans. As in British Columbia, the complete details of the new regulatory system will not be known until the regulations are published and finalized. We will closely follow legislative developments and be prepared to assist clients with the challenges and opportunities presented by new legislation in Alberta and British Columbia. New Ontario Regulations Provide Anticipated Funding Flexibility In brief: zamortization period for new solvency deficiencies extended to 10 years zmay also consolidate existing solvency payment schedules s into a single new payment schedule zpermanent 1-year deferral of new solvency and going concern amortization payments zdeadline for filing actuarial reports with valuation dates between September 30, 2011, and May 31, 2012, is February 28, 2013 Despite the prorogation of the Ontario Legislature on October 15th, the Cabinet is continuing to meet, and the regulations related to the long-awaited further round of solvency funding relief for Ontario-registered underfunded pension plans were able to proceed. On November 2, 2012, Regulation 329/12, amending 2012 Morneau Shepell November 2012 Volume 9, issue 11 2 of 11

3 Regulation 909 made pursuant to the Ontario Pension Benefits Act, R.S.O. 1990, as amended, was published on e-laws. The 2012 Ontario Budget announced that the government would provide two temporary funding relief measures in respect of the first valuation report filed with a review date on or after September 30, 2011: extending the amortization period for new solvency deficiencies from five to 10 years and consolidating existing solvency payment schedules into a single new payment schedule. Regulation 329 provides the two temporary measures. There is a requirement to communicate to plan members when one of the two temporary measures is elected; and where the sponsor wishes to extend the amortization period to 10 years it is only possible if no more than 1/3 of plan members object. The 2012 Ontario Budget also reiterated two previously promised permanent funding relief measures: delaying the commencement of the new amortization period to one year after the review date and permitting the use of letters of credit to offset special payments. Regulation 329 confirms, on a permanent basis, that the commencement of new amortization periods for special payments to liquidate a solvency deficiency or going concern unfunded liability may be delayed to one year after the review date. There is no requirement to give notice to members of the use of this provision. Regulation 329 does not cover letters of credit. The Regulation permits companies, whether or not they have previously taken advantage of solvency relief in respect of a valuation report with a valuation date on or after September 30, 2008, and before September 30, 2011, to secure relief in respect of the first report filed for which the valuation date is on or after September 30, 2011, and before September 30, The rules related to these further relief measures are technically complex but basically duplicate the rules that were developed when solvency relief was first permitted in Ontario. Morneau Shepell published News & Views articles about the original solvency relief rules on July 17, 2009, and October 20, Finally, Regulation 329/12 permits Ontario plan administrators to file the first valuation report due on or after September 30, 2011, and before May 31, 2012, by February 28, Proposed Mortality Table and IMProvement Scale will Increase CanadIAn Pension Liabilities Canadian pensioner mortality experience studies may result in a new mortality table and improvement scale that, if adopted in the actuarial standards of practice, will likely increase pension liabilities between 3% and 8% depending on the demographics of the pension plan. This information came to light at the Canadian Institute of Actuaries Pension Seminar on November 5, 2012, where two of five sessions were dedicated to the question of Canadian life expectancy. In one session, the results of two recently completed studies of Canadian pensioner mortality experience were presented: one study used data from several public and private sector registered pension plans while the other used data from the CPP/QPP. The results of the first study were used to create a proposed mortality table (with a base year of 2004) while the results of the second study were used to create a proposed mortality improvement scale. Longevity improvements are seen across the board, but are significant for males around age 65 (at this age liabilities will increase by 8.2%). Other studies have shown a similar tendency towards longer life expectancy (i.e. pensioners receiving pension payments for longer periods of time), however, both of these studies are the first of their kind to specifically focus on Canadian pensioner mortality experience. The final reports for both studies are expected in the coming months so it is likely that 2012 Morneau Shepell November 2012 Volume 9, issue 11 3 of 11

4 the current mortality table and improvement scale used to value pension benefits will be modified sooner rather than later. For pension plan sponsors, this change means: zincreases in pension plan liabilities (depending on the age/sex distribution of plan members, we expect that liabilities will increase between 3% and 8%). zincreases in payments of commuted values. zgreater emphasis on managing the plan s longevity risk (see article on annuities in this issue). Buying Annuities for Defined Benefit Plans: Why Not? Defined benefit pension plans are currently looking for solutions to manage their risk. Oddly, buying annuities is seldom included in the strategies contemplated for this purpose. Nevertheless, it is relevant to consider how buying annuities for a defined benefit plan works and how annuities can be integrated into a comprehensive risk management strategy. By buying annuities for its retired members from an insurance company, the pension plan sponsor obtains a guarantee that a pension will be paid to its members throughout their lifetime. The pension plan not only offloads the longevity risk (the risk that a member will survive longer than expected), but the market and interest rate risks as well. In fact, buying annuities would have mitigated, to a certain extent, the poor returns and interest rate drops of 2008 and 2011, which resulted in substantial pension plan deficits. Hedging interest rate risk is also possible using liability driven investing strategies that mainly rely on bonds. In some circumstances, annuities may become even more attractive than bonds. This is because insurers can back their annuities with investments that offer more appealing returns, such as mortgages and private investments. Insurers may be more or less interested in offering annuities in any given year; pricing will depend on their budget, sales objectives, coverage needs and available investments. It would therefore be advisable to keep an eye out for good opportunities in order to pre-emptively purchase annuities and reduce the total cost of buying annuities. The longevity risk may sometimes appear insignificant compared to the other risks pension plans have to deal with. It is quite possible, though, that some scientific discoveries or technological advances could substantially increase our life expectancy. Some believe that someone currently living on this Earth will live to the ripe old age of 150! Therefore, actuaries will probably have to continue to change the mortality tables they use (see article on possible changes to mortality tables in this edition of News & Views), which could entail significant losses for pension plans. Does a plan sponsor really want to assume this risk? Insurers on the other hand are certainly well equipped to deal with the longevity risk. Pooling allows for better diversification, and insurers must comply with strict rules for preserving capital in order to prevent losses. Under legislation in many jurisdictions, closed plans must be terminated and they must purchase annuities when they no longer have active members. However, it is risky to wait for the last active member to retire before starting to purchase annuities. Interest rates may be especially low at that time, resulting in losses and requiring special contributions by the plan sponsor, or even a reduction in benefits in the event of the latter s bankruptcy. Therefore, it may be well advised for these plans to adopt a dynamic annuity buying program. What role do annuities play in an investment policy? To answer this question, we must see annuities as an investment and not as an expenditure. In fact, an annuity is quite similar to a bond, because it consists of a series of payments spread out over a long period. It is therefore preferable to use a fixed income investments rather than equities to finance annuity purchases Morneau Shepell November 2012 Volume 9, issue 11 4 of 11

5 One of the major problems with buying annuities remains pension indexation. Inflation hedging may be very costly, because the assets used to offset inflation are scarce and expensive. One alternative would be to buy indexed annuities at a flat percentage per annum, say 2%. However, if inflation exceeds 2%, the plan must absorb the loss. In last month s News & Views, we saw that individuals may benefit from purchasing annuities. This month, we maintain that the benefits of purchasing annuities are also indisputable for defined benefit pension plan. Although this strategy is often overlooked, it should certainly be part of overall risk management. care plans and requires a pooling threshold equal to or less than $25,000. Renewals for eligible plan sponsors effective on or after January 1, 2013, will take the industry pooling arrangement into account. For additional information pertaining to the above changes, please contact your Morneau Shepell consultant. Who DeterMInes the AssuMPtions for Pension Plans? Group BeneFIt Changes effective January 1, 2013 As the New Year approaches, it is a prudent time to reiterate two changes announced earlier in 2012 that may impact group benefit programs and will take effect January 1, The May 2012 News & Views outlined the 2012 Federal Budget s impact on the taxability of critical illness and accidental death and dismemberment (AD&D) premiums. Employer contributions to these benefits will be taxable to the employee for income tax purposes. The change means employees are subject to tax on the employer contributions that relate to coverage in 2013 and beyond. Contributions made for coverage in 2013 will be included in the employee s income for 2013, even if these contributions are made between March 29, 2012, and December 31, We recommend plan sponsors ensure that applicable changes are made to internal administrative procedures and that communication of these changes to plan members is released in due course. The June 2012 edition of News & Views detailed the industry wide prescription drug pooling arrangement announced by the Canadian Life and Health Insurance Association. The agreement has been signed by all 24 Canadian insurance companies. The arrangement impacts fully insured, non-refund extended health How pension plans are valued impacts a plan sponsor s cash contributions to the plan and the amount of pension expense reported in its financial statements. Where costs are shared between members and employers, the valuation of a defined benefit (or target benefit) pension plan also impacts member contributions or benefits. So who determines the assumptions that are so critical in establishing the value of a pension plan? There are three common valuation bases for pension plans. For the purpose of this article, we will concentrate on the going-concern basis. In the past, assumption setting was almost exclusively the domain of the actuary. The actuary decided on the range of acceptable assumptions and often selected which assumptions to use for a given pension plan. These assumptions almost always included some conservatism, or what we now refer to as a margin for adverse deviations. Usually, the actuary discussed the range of acceptable assumptions with the plan sponsor since the plan sponsor would ultimately be required to make the resulting contributions. However, it was not a requirement for the actuary to seek formal instructions on which assumptions to use or which margins to reflect. This process changed on December 31, 2010, when the Canadian Institute of Actuaries made changes to its Pension-Specific Standards of Practice. These 2012 Morneau Shepell November 2012 Volume 9, issue 11 5 of 11

6 changes included a requirement that plans be valued using best-estimate assumptions (with limited, but important, exceptions). In other words, the financial position of the plan and the plan sponsor s minimumrequired contributions need to be determined using assumptions that do not include any provision for adverse events. The use of best-estimate assumptions results in the plan achieving its assumed return on assets (i.e. discount rate) over the long term 50% of the time. The exceptions to this change are that margins for adverse deviation can be included to the extent required by law or by the terms of an engagement. Therefore, the Standards do not permit an actuary to include any conservatism in their assumptions unless they have specific direction to do so from either the law or the entity that provides the actuary with their terms of engagement. But the question is: which entity is able to provide these terms of engagement? The Canadian Association of Pension Supervisory Authorities (CAPSA) has partially addressed this question in its Pension Plan Funding Policy Guideline (Guideline No. 7, dated November 15, 2011). While they do not specifically address who can formally provide an actuary s terms of engagement, they are very clear on the plan sponsor s role in providing guidance on margins for adverse deviation: The plan sponsor can provide useful guidance to the plan actuary in selecting actuarial methods and assumptions that are appropriate for the plan sponsor s risk management approach. This guidance can include the going concern actuarial cost method, desired margins or provision for adverse deviations and acceptable asset valuation methods and ranges. The plan administrator would provide information on data, investments, historical experience, etc. to assist the actuary in developing these assumptions. This combined input would normally be reflected in the actuary s selection of methods and assumptions in particular, the margins for adverse deviations provided they do not lead to assumptions that deviate from accepted actuarial practice. (emphasis added) VALUATION Bases There are primarily three valuation bases for pension plans: Accounting basis llrequirement under accounting standards llimpacts an organization s financial statements lldiscount rate is established based on a prescribed methodology llbest-estimate assumptions are selected by management Solvency basis llrequirement of pension benefits legislation llimpacts cash contributions if the plan is in deficit on this basis (with some exceptions) llassumes that the plan was wound up on the valuation date, with permissible adjustments allowed under legislation of different jurisdictions llassumptions reflect market conditions as the valuation date Going-concern basis llrequirement of pension legislation llimpacts the cash contributions in respect of normal cost (future service accruals) llimpacts cash contributions towards past service if the plan is in deficit on this basis llthe Plan is assumed to continue indefinitely; consequently, the assumptions generally reflect a long time horizon This Guideline could therefore be construed to indicate that margins for adverse deviation were within the purview of the plan sponsor. Consequently, it was quite surprising when the Régie des rentes du Québec released its Newsletter Express, in May 2012, in which they took the position that it is the plan administrator s role to provide instructions on the margins for adverse deviation. In Quebec, the plan administrator is a pension committee as opposed to the plan sponsor (although the plan sponsor will usually have some representation on the committee) so this position is significant. The pension committee s duties do not 2012 Morneau Shepell November 2012 Volume 9, issue 11 6 of 11

7 include an obligation to consider the plan sponsor s tolerance for a level of pension contributions. It can therefore instruct the actuary to a large margin for adverse deviation in its assumptions, thereby potentially leading to contributions that are greater than the plan sponsor would have otherwise paid. So, back to our original question: who determines the assumptions for pension plans? The answer is the actuary, but not only the actuary. The other players in the game will depend on the jurisdiction governing funding of the plan and the entity that provides the actuary with its terms of engagement with respect to margins Morneau Shepell November 2012 Volume 9, issue 11 7 of 11

8 As at October 31, 2012 Market Indices The following table shows the Morneau Shepell monthly summary of returns from various market indices. It also includes returns from benchmark portfolios used by pension funds. Monthly Quarter to date RETURNS Year to date 1 year tsx GROUP/PC BOND Indices DEX Universe Bond -0.2% -0.2% 3.1% 5.7% DEX 91 Day Treasury Bill 0.1% 0.1% 0.8% 1.0% DEX Short Term Bond 0.1% 0.1% 1.8% 2.4% DEX Mid Term Bond -0.1% -0.1% 4.2% 6.6% DEX Long Term Bond -0.8% -0.8% 4.2% 10.5% DEX High Yield Bond 1.9% 1.9% 13.0% 14.7% DEX Real Return Bond 0.0% 0.0% 2.8% 8.1% CANADIAN EQUITY Indices S&P/TSX Composite (Total Return) 1.1% 1.1% 6.5% 4.5% S&P/TSX Composite Capped 1.1% 1.1% 6.5% 4.5% S&P/TSX MegaCap 1.1% 1.1% 5.3% 3.5% S&P/TSX 60 (Total Return) 1.5% 1.5% 7.2% 5.1% S&P/TSX Completion 0.0% 0.0% 4.7% 2.8% S&P/TSX Small Cap -0.4% -0.4% -0.6% -4.2% BMO Small Cap Unweighted -0.7% -0.7% 0.5% -3.6% BMO Small Cap Weighted -0.3% -0.3% 3.3% 0.2% U.S. EQUITY INDICES S&P 500 (US$) -1.8% -1.8% 14.3% 15.2% S&P 500 (C$) -0.3% -0.3% 12.3% 15.5% FOREIGN EQUITY INDICES 1 MSCI ACWI (C$) 0.9% 0.9% 10.1% 9.2% MSCI World (C$) 0.9% 0.9% 10.2% 10.1% MSCI EAFE (C$) 2.4% 2.4% 9.0% 5.3% MSCI Europe (C$) 3.1% 3.1% 10.8% 6.8% MSCI Pacific (C$) 1.2% 1.2% 5.7% 2.6% MSCI Emerging Markets (C$) 1.0% 1.0% 9.6% 3.6% other Consumer Price Index (Canada, September 2012) 0.2% 0.3% 1.5% 1.2% Exchange Rate US$/C$ 1.6% 1.6% -1.8% 0.2% MORNEAU SHEPELL BENCHMARK PORTFOLIOS 2 60% Equity/40% Bonds 0.5% 0.5% 6.3% 6.7% 55% Equity/45% Bonds 0.5% 0.5% 6.0% 6.6% 50% Equity/50% Bonds 0.4% 0.4% 5.8% 6.5% 45% Equity/55% Bonds 0.3% 0.3% 5.5% 6.5% 40% Equity/60% Bonds 0.3% 0.3% 5.2% 6.4% ASSET & RISk MANAGEMENT In Asset Management, we provide objective advice on all aspects of asset management for pension funds, including investment policy statements, portfolio manager searches, investment performance measurement and investment strategy. Jean Bergeron, FSA, FCIA, CFA, Partner Tel.: Fax: jbergeron@morneaushepell.com Robert F. Boston, CFA, Partner Tel.: Fax: rboston@morneaushepell.com In Risk Management, we provide a structured, comprehensive approach to pension risk management, including implementation of liability-driven investment strategies, advice on allocation of the risk budget within an asset-liability framework and execution of continuous and dynamic processes for risk reduction. Patrick De Roy, FSA, FCIA, CFA, FRM, CERA, Partner Tel.: Fax: pderoy@morneaushepell.com 1 Returns net of taxes on dividends, except for MSCI Emerging Markets. 2 The returns are compounded monthly Morneau Shepell November 2012 Volume 9, issue 11 8 of 11

9 As at October 31, 2012 Tracking the Funded Status of Pension Plans This graph shows the changes in the financial position of a typical defined benefit plan since December 31, For this illustration, assets and liabilities of the plan were each arbitrarily set at $100 million as at December 31, The graph shows the impact of past returns on plan assets and the effect of interest rate changes on solvency liabilities The Evolution of the FinancIAl Situation of Pension Plans since December 31, 2007 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q Assets ($M) Solvency Liabilities ($M) In October 2012, assets rose slightly while liabilities were relatively stable. Due to positive returns in Canadian and most international equity markets, assets increased by 0.5% to about $115.2 million, their highest level experienced during the period shown. Moreover, solvency liabilities remained somewhat stable, increasing by only 0.1% to $157.2 million. The combined result was that the deficit has decreased this month by 1.0% to $42.1 million. Nonetheless, over the last 6 months this typical pension plan has shown solvency deficits at levels well beyond those seen previously in the time period shown. Since the beginning of the year, the funded status of this typical pension plan has deteriorated. The deficit has increased by $4.1 million (a 10.9% increase). Please contact your Morneau Shepell consultant for a customized analysis of your pension plan. Comments: canada Bond Yields YIeld (closing) DEC Oct CHANGE 2012 Overnight rate target 1.00% 1.00% 0 bp 3 months 0.82% 0.99% 17 bps 2 years 0.95% 1.07% 12 bps 5 years 1.27% 1.34% 7 bps 7 years 1.51% 1.51% 0 bp 10 years 1.94% 1.78% -16 bps 30 years 2.49% 2.38% -11 bps Source: Bank of Canada 1. No consideration has been made for contributions paid to the plan or for benefits paid out of the plan. 2. Solvency liabilities are projected using the rates prescribed by the Canadian Institute of Actuaries for the purpose of determining pension commuted values. Early application of the 2009 standards is not reflected. 3. The underlying typical defined benefit plan is a final average plan with no pension indexing. 4. Solvency liability calculations take into account revised CIA guidance on the solvency valuation assumptions (annuity proxy). 5. Assets are shown at full market value. Returns on assets are based on those of the Morneau Shepell benchmark portfolio (55% equities and 45% fixed income) Morneau Shepell November 2012 Volume 9, issue 11 9 of 11

10 As at October 31, 2012 IMPAct on Pension Expense under International Accounting Every year, companies must establish an expense for their defined benefit pension plans. The following graph shows the expense impact for a typical pension plan that starts the year at an arbitrary value of 100 (expense index). The expense is influenced by changes in the discount rate based on high quality corporate and provincial (adjusted) bonds and the median return of pension fund assets Expense Index from December 31, 2011 Contributory plan Non-contributory plan (In %) Discount rate Return on assets (55% equities) n/a , The pension expense has risen by 15% (for a contributory plan) since the beginning of the year due to the decrease in the discount rate since December 31, However, this month, the discount rate was in fact slightly higher, so the pension expense decreased in October. The table below shows the discount rates for varying durations and the change since the beginning of the year. A plan s duration generally varies between 10 (mature plan) and 20 (young plan) Please contact your Morneau Shepell consultant for a customized analysis of your pension plan. Comments: 1. The discount rates shown reflect the educational note published by the Canadian Institute of Actuaries entitled Accounting Discount Rate Assumption for Pension and Post-employment Benefit Plans (September 2011). 2. The expense is established as at December 31, 2011, based on the average financial position of the pension plans used in our 2011 Survey of Economic Assumptions in Accounting for Pensions and Other Post-Retirement Benefits report (i.e. a ratio of assets to obligation value of 85% as at December 31, 2010). Also, we are assuming that, under the international accounting, the employer elected the exemption at transition with regards to past gains and losses, and that future gains and losses are recognized in other comprehensive income (excluded from expenses shown). 3. The return on assets corresponds to the return on the Morneau Shepell benchmark portfolio (55% equities and 45% fixed income). 4. The actuarial obligation is that of a final average earnings plan, without indexing (two scenarios: with and without employee contributions). DURATIon Discount rate december 2011 October 2012 CHANGE IN % 3.63% -53 bps % 3.82% -57 bps % 3.95% -56 bps % 4.03% -55 bps 2012 Morneau Shepell November 2012 Volume 9, issue of 11

11 About Us Morneau Shepell is the largest Canada-based human resource consulting and outsourcing firm focused on pensions, benefits, employee assistance program (EAP) and workplace health management and productivity solutions. We offer business solutions that help our clients reduce costs, increase employee productivity and improve their competitive positions by supporting their employees financial security, health and Calgary London Québec Fredericton Montréal St. John s Halifax OTTAWA TORONTO Kitchener Pittsburgh VANCOUVER info@morneaushepell.com morneaushepell.com ContribuTING EdITors Patrick Duplessis, FSA, CERA Asset & Risk Management Greg Heise, FSA, FCIA, FCA Retirement Consulting Francine Pell, FSA, FCIA Retirement Consulting Emily J. Tryssenaar, FSA, FCIA Retirement Consulting Bethune Whiston, J.D. Pension Legislation David White, CEBS, BBA Benefits Consulting Andrew Zur, LL.B. Pension Legislation Please contact your Morneau Shepell consultant for additional information about this newsletter Morneau Shepell November 2012 Volume 9, issue of 11