Disclosure of Large Pension Plan Investments

Summary#

The Regulations Amending the Pension Benefits Standards Regulations, 1985 (Publication of Information Relating to the Investments of Plans) are a proposed change published in the Canada Gazette on November 2, 2024. They would require the Office of the Superintendent of Financial Institutions (OSFI) to publish, in a standard format, where large federally regulated private pension plans invest — by geographic region and by asset type — with the first public data covering 2022, 2023 and 2024 plan years.

What it does#

• Sets a size threshold: any federally regulated private pension plan with total assets of $500 million or more must have its investment distribution published.
• Requires OSFI to publish, for each covered plan:
  • assets under management by market value (dollars) and as a percentage of total assets, broken down by geographic location and by asset class within each location.
  • separate presentation for assets tied to defined benefit and defined contribution provisions.
  • identification by employer for single‑employer plans and by plan name for multi‑employer plans, plus an aggregate for all plans.
• Prescribes geographic groups: Canada, United States, Europe, China, Asia‑Pacific (excluding China), Latin America, and other.
• Prescribes asset classes: public equities, private equities, bonds, infrastructure, real estate, short‑term assets (cash, deposits, GICs, short‑term securities), and other.
• Requires OSFI’s first publication to cover plan years ending in 2022, 2023 and 2024.
• These rules were proposed under authority added to the Pension Benefits Standards Act, 1985 by Budget 2024 (royal assent on June 20, 2024) and are open for comment for 30 days after the Gazette notice.

Who's affected#

• Large federally regulated private pension plans — about 50 plans that have $500 million or more in assets. Those plans hold roughly $210 billion, about 89% of federally regulated pension assets.
• Plan administrators, who will need to provide the detailed breakdowns to OSFI. That may involve asking actuaries or asset managers for existing reports.
• Plan members and retirees of these plans, who will see more public detail about where their pensions are invested.
• OSFI, which will collect and publish the data.
• Broader context: there are about 1,180 federally regulated plans with total assets of about $238 billion, but most (plans below the $500 million threshold) would not be included. Small businesses generally would not be affected.

Why it matters#

• It makes the investment mix of the largest federally regulated private pension plans easier for the public and plan members to compare.
• Members and retirees can get clearer information on geographic exposure (for example, how much is invested in Canada versus China or the United States) and on asset types (for example, stocks versus real estate).
• OSFI and the public will have more standardized data to monitor pension investments and risks across plans.
• The government expects the change to have minimal direct cost to plans because much of the information already exists in plan records. The policy may also encourage similar disclosures in provincial pension systems, improving comparability across Canada.