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Regulations under the Pooled Registered Pension Plans Act, 2015

Release Date: 08/19/2016
Staff Reference: Ron Sanderson

August 19, 2016

Draft Regulations under the PRPP Act
Pension Initiatives Unit, Pension Policy Branch
Ministry of Finance
5th Floor, Frost Building South
7 Queen's Park Crescent East
Toronto, ON
M7A 1Y7

Dear Sir or Madam:

Proposal Number: 16-MOF019
Regulations under the Pooled Registered Pension Plans Act, 2015

The Canadian Life and Health Insurance Association (CLHIA) is pleased to provide the following comments and recommendations with respect to Ontario's proposed Regulations under the Pooled Registered Retirement Plans Act, 2015 (the "PRPP Act").

CLHIA members are key service providers to defined contribution pension plans for predominantly small- and medium-size employers. Workplace retirement plans like DC pensions, group RRSPs and PRPPs provide an important complement to benefits available under the Old Age Security program and the Canada Pension Plan.

We believe that saving in the workplace is easiest, and most efficient for consumers. As such, our industry strongly supports PRPPs, which offer flexible, low cost, savings options to Ontario workers.

Canada's life and health insurance companies encourage the Ontario government to refine its PRPP legislation to further strengthen retirement savings. We urge Ontario to follow Quebec's lead, making access to a workplace retirement plan, be it a pension plan, group RRSP, group TFSA or a PRPP, a requirement in all workplaces with more than a prescribed number of employees. This approach facilitates secure retirement incomes for Ontario workers, while recognizing the need of some workers to focus on other financially-prudent, near-term, alternatives, such as debt repayment.