CAP Self-Assessment Tool - Sun Life€¦ · Service providers include any provider of service or...

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CAP Self-Assessment Tool

Transcript of CAP Self-Assessment Tool - Sun Life€¦ · Service providers include any provider of service or...

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Benchmark your current practicesThe Joint Forum of Financial Market Regulators released the final version of the CapitalAccumulation Plan (CAP) Guidelines on May 28th, 2004.

The CAP Guidelines are intended to outline and clarify the rights and responsibilities ofCAP sponsors, service providers and CAP members, and to ensure that CAP members areprovided the information and assistance that they need to make investment decisionsin a capital accumulation plan.

This CAP Self-assessment Tool will help you determine your level of compliance withthe CAP Guidelines. Please consult with your benefits consultant or plan advisor whenreviewing your capital accumulation plan and your compliance with the CAP Guidelines.

How to use the CAP Self-assessment Tool1. Answer the questions on the following pages by choosing the appropriate box and

keying your detailed response(s) in the space(s) provided.

Beside each question is a summary of the service(s) Sun Life Financial Group RetirementServices (referred to in this document as “SLF”) already provides (or can provide) tosupport you in this regard.

2. You may edit your responses at any time.

3. When you have completed the self-assessment, print a copy for your file. This tool couldbe a useful part of your overall plan governance documentation. As this document isin an Adobe Acrobat (PDF) file format, the document cannot be saved with your answers.

Note: Sun Life Financial may be only one of various suppliers you use to deliver a CAP. You will want toreview each question included in this tool with each of the suppliers you use.

Sun Life Financial assumes no liability with respect to the use of this tool.

This document cannot be saved with your answers.mm/tw 11_05_e

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Capital Accumulation PlanA capital accumulation plan is a tax assisted investment or savings plan that permits the members to make investment decisions among two or more options offered within the plan. This may include a defined contributionregistered pension plan; a group registered retirement savings plan or registered education savings plan; and a deferred profit sharing plan.

CAP SponsorsEmployers, trade unions, or associations that establish capital accumulation plans are referred to as CAP sponsors. If the CAP is a registered pension plan, many of the responsibilities of the CAP sponsor are those of a pension plan administrator.

When CAP sponsors decide to establish a plan, they assume certain responsibilities. These responsibilities could be delegated to a service provider.

Broadly speaking, the CAP sponsor is responsible for:• Setting up the plan,• Providing investment information and decision making tools to

CAP members,• Introducing the plan to members,• Providing on-going communication to members – communication

should use plain language and be in a format that ensures readability,• Maintaining the plan,• Ensuring that termination of the plan or the membership of an individual

within the plan is done in accordance with the terms of the CAP, and• Meeting any applicable legal requirements, including any requirements

that may extend beyond the scope of the Guidelines.

The CAP sponsor should ensure that all decisions regarding the establishmentand maintenance of the CAP and the process for making those decisionsare properly documented and the documents retained. They should alsobe made with a view to the purpose behind the creation of the CAP.

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When reading the CAP Guidelines, it is important to understand what isdefined as a capital accumulation plan and what are the responsibilitiesof each of the parties involved – plan sponsor, plan member and serviceprovider. Following are the definitions and explanations of responsibilitiescontained in the CAP Guidelines.

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Service ProvidersService providers include any provider of service or advice required bythe CAP sponsor in the design, establishment and operation of a CAP.The CAP sponsor may delegate responsibilities outlined in the Guidelinesto a service provider in which case the service provider is responsiblefor following the Guidelines and any applicable legal requirements.

Service providers engaged by CAP sponsors should have the appropriateknowledge and skill to perform the tasks they are delegated and to provideany advice within their area of expertise requested by the CAP sponsor.

CAP MembersCAP members are individuals who have assets in a capital accumulation plan. This may include active or former employees; trade union orassociation members; and in certain cases, their spouses or commonlaw partners.

CAP members are responsible for making investment decisions withinthe plan and for using the information and decision-making tools availableto assist them in making those decisions. In addition, CAP membersshould also consider obtaining investment advice from a qualified individual.

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Investment OptionsThe investment options that may be offered in a CAP are governed by legislation. Sponsors must comply with applicable legislation when choosing the options for the CAP.

Examples of investment options include:• Investment funds,• Guaranteed investment certificates (GICs),• Annuity contracts,• Employer securities,• Government securities,• Other securities, and• Cash.

In the Guidelines, the term investment fund refers to a mutual fund,pooled fund, segregated fund or similar pooled investment product.

If investment funds are offered in a CAP that is a registered pension plan, the funds must comply with the investment rules under applicable pensionbenefits standards legislation.

If the investment fund is a mutual fund under securities law, the fundmust comply with the investment rules that govern conventional publicmutual funds. As of the date of the release of the final Guidelines (May28, 2004) the mutual fund must comply with the investment rules underNational Instrument 81-102 Mutual Funds.

If the investment fund is an insurance product, the fund must comply with:• The investment rules applicable to individual insurance contracts; or• The investment rules that govern conventional public mutual funds; or• The investment rules under applicable pension benefits

standards legislation.

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1. Does your CAP have a clearly defined purpose?

Yes Somewhat No Not sure

If Yes : a. Have you documented the purpose? If so, how?

b. Has your CAP’s purpose been communicated to plan members? If so, how and when?

c. Have you established a regular review and communication timetable?

If Somewhat , No or Not sure : When will you have a defined purpose? Who will develop it? How and when it will be communicated?

Note: If at a later date you decide to change the purpose of the plan, the modified purpose ofthe plan should be documented and communicated in a similar manner as above.

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Setting up a CAPSE

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SLF CAP READINESS:Your Sun Life Financial Group Retirement Services representative can assist you andprovide sample Statements ofPurpose as well as help develop aplan to communicate the purposeto your plan members.

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2. Are you confident that members understand their responsibilities within the CAP?

Yes Somewhat No Not sure

If Yes : a. How (face-to-face, print, electronic, etc.) and how often (quarterly,

yearly, during initial enrolment, etc.) have these responsibilities beencommunicated to them?

If Somewhat , No or Not sure : How and when will you communicate to members about their CAP responsibilities?

3. Have you documented the criteria used to select serviceproviders (e.g. professional training; experience; quality;level and continuity of services offered, etc. Please referto Section 2 .1 .3 of the Guidelines)?

Yes No

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SLF CAP READINESS: Member responsibilities in a CAP are outlined on the Sun LifeFinancial Plan Member Serviceswebsite as well as in our what?me save? Guide to Saving andInvesting. Your Sun Life FinancialGroup Retirement Services representative can help youdevelop a plan to communicateto your plan members to ensurethey understand their responsi-bilities with the CAP.

SLF CAP READINESS:Your Sun Life Financial GroupRetirement Services represent-ative can provide an overview ofSLF’s capabilities with respect tothe CAP Guidelines.

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4. Have you documented each service provider’s role and responsibilities?

Yes No

5. In selecting the CAP’s investment options, did you considerthe following:The appropriate number and type of investment options to reflect the purpose of the CAP? Yes No

The legal limitations on the types of investments that may be offered for your particular CAP? Yes No

The fees associated with the investment options? Yes No

The help of a service provider in selecting appropriate investment options? Yes No

Your ability to periodically review the options selected? Yes No

The diversity and demographics of your CAP members? Yes No

The liquidity of investment options? Yes No

The degree of diversification among investment options available? Yes No

The level of risk associated with the investment options? Yes No

Reasonable opportunities for plan members to transfer freely among options (at least quarterly)? Yes No

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SLF CAP READINESS:Through our comprehensiveInvestment Manager Program(IMP), we offer a broad selectionof investment options and theflexibility for plan members totransfer among funds. The IMPcombines essential aspects of manager oversight (investmentmanager selection, monitoringand review, communication andpricing) with access to detailedfund information and analysis viaMorningstar Canada, a third partysupplier, to support sponsorfund selection. In addition, thePlan Sponsor Services websiteprovides current rate of returninformation as well as reportsillustrating member demographicinformation. Sun Life Financialalso offers a comprehensiverange of guaranteed investmentoptions.

Your Sun Life Financial GroupRetirement Services represent-ative and your EducationSpecialist can work with you tohelp assess the diversity anddemographics as well as financialknowledge of your plan members.They can then assist you to developan education strategy specific tothe needs of your plan members.

SLF CAP READINESS:Our Service & Fee Agreementdescribes SLF’s role andresponsibilities.

Comments:

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6. In selecting the CAPs investment funds, did you consider the following?

The attributes of the investment funds such as the investment objectives, investment strategies, investment risks, the manager(s) historical performance and fees? Yes No

Whether the investment fund(s) selected provide CAP members with options that are diversified in their styles and objectives? Yes No

* Note: The investment funds must comply with the investment rules applicable to the type ofinvestment fund. Please refer to section 2.2.2 of the CAP Guidelines.

7. Have you established a policy to deal with plan memberswho fail to make investment choices?

Yes No

If Yes : a. Have you documented it? Yes No

b. Has it been communicated to plan members? Yes No

c. Have you established a regular review timetable for this policy? Yes No

If No : When will you have a policy? Who is responsible for its development?How will it be communicated to plan members?

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SLF CAP READINESS:Through our comprehensiveInvestment Manager Program (IMP),we offer a broad selection ofoptions. The IMP combines essentialaspects of manager oversight (investment manager selection,monitoring and review, communi-cation and pricing) with access todetailed fund information andanalysis via a third party supplierto support sponsor fund selection.In addition, the Plan SponsorServices website provides currentrate of return information.Sun Life Financial also offers a comprehensive range of guaranteedinvestment options.

SLF CAP READINESS:A default option, carefullyselected with regard to the purpose of the CAP, might formthe core of such a policy. YourGroup Retirement Services representative and an SLFInvestment Services Executive,working with your benefits consultant or plan advisor, canhelp you to establish sucha policy and then communicate this policy to your plan members.

Your Education Specialist canalso work with you to create a customized education and communication plan to ensurethat your plan members areaware of all of their investmentoptions and the value of creatingan asset mix strategy.

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8. Have you developed a recordkeeping and document retention program for your CAP?

Yes No

If Yes : a. Have you documented it? Yes No

b. Have you established a review timetable for it?

Yes Annually Quarterly No

If No : When will you have a recordkeeping and document retention program?Who is responsible for its development and maintenance?

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SLF CAP READINESS:The annual business plan preparedby your Group RetirementServices representative can helpform part of your recordkeepingand document retention program.

In addition, our independent,semi-annual ISO 9001:2000 audithelps assure plan sponsors thatmember records are maintainedusing carefully monitored andcontrolled business practices.

Our document retention policydescribes the types of documentswe retain as a service provider aswell as the length of time thedocument is retained.

We regularly review and update ourDocument Retention Policy.

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1. In determining appropriate decision-making tools, did you consider:

The purpose of the plan? Yes No

The types of decisions members must make? Yes No

Costs of the information and decision-making tools? Yes No

The location, diversity of plan members (example: language, physical abilities)? Yes No

Members’ access to computers and the Internet? Yes No

2. Do you provide CAP members with investment informationthat covers the following:

How investment funds work? Yes No

Investing in securities (stocks, bonds)? Yes No

The relative expected risk and return for various investment options? Yes No

Glossaries of investment terms? Yes No

Product guides? Yes No

Performance reports for any investment options offered in the CAP? Yes No

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SLF CAP READINESS:Our multi-language service availablethrough our Customer Care Centregives plan members the ease andconfidence of discussing theirretirement plan in their own language. A hearing-impaired line is also available.

In addition, key decision-makingtools are available in large printfor plan members who haveimpaired vision. The AssetAllocation tool and RetirementPlanner are both available in printfor those members who do nothave access to the Internet.

SLF CAP READINESS:Our multi-media plan membercommunication and educationprogram covers substantially allaspects outlined in the Guidelines.In addition, your Sun Life FinancialEducation Specialist can workwith you to develop an educationstrategy specific to the needs ofyour plan members.

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3. Do you provide CAP members with the following decision-making tools:

Asset Allocation Models? Yes No

Retirement planning tools to help members estimate retirement income needs? Yes No

Calculators and projection tools? Yes No

Investor Profile tools to help members self-assess risk tolerance? Yes No

4. Do you make investment advice available to CAP members?

Yes No

If Yes : How is the investment advice delivered?

Face-to-Face Electronically Print (newsletter/bulletin)

None

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SLF CAP READINESS:Sun Life Financial provides plan members with a number of interactive decision-makingtools focused on retirement planning including the InvestmentRisk Questionnaire (an asset allocation tool), RetirementPlanning Tool, Budget Calculator,Investment Return Calculator and Net Worth Calculator via thePlan Member Services website atwww.sunlife.ca/member. In addition,paper-based worksheets for theInvestment Risk Questionnaireand the Retirement Planner areavailable on their own and in thewhat? me save? Guide to Savingand Investing.

Key decision-making tools arealso available in large print for plan members who haveimpaired vision.

Early in 2006, we will launch newand improved decision-makingtools.

SLF CAP READINESS:Sun Life Financial can provideaccess to advisory services thatcan be tailored to meet yourneeds if you choose to offeradvice to your plan members. Advicecan be limited to investments orextended to full personal financialplanning services and can bedelivered by phone or face-to-face.

Other:

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5. Have you recommended that CAP members access additional investment advice independently?

Yes No

6. If you have selected a service provider to deliver investment advice to CAP members, did you consider:

The professional qualification/licensing/accreditation of the advisor? Yes No

The professional reputation of the advisor? Yes No

The advisor’s experience with employee benefits, pension legislation and related rules? Yes No

The overall corporate stability of the organization? Yes No

Any real or perceived lack of independence/conflict of interest? Yes No

The advisor’s ability to deliver a consistent level of service in all regions? Yes No

Any complaints filed against the advisor or his/her firm and any disciplinary actions taken (if any) Yes No

7. If you currently make plan member information availableto third parties, have you obtained written individual planmember consent to do so?

Yes No

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SLF CAP READINESS:In both the what? me save? Guideto Saving and Investing (online andin paper) and in education sessions,plan members are advised to consider independent investmentadvice from investment or financialplanning professionals. This messagealso appears on the Plan MemberServices website and is included inplan-specific communication whereappropriate.

SLF CAP READINESS: SLF can provide access to advisoryprograms that can be tailored to suit the needs of your plan.Individual advice can be limitedto investment planning or extendedto full personal financial planning,and can be delivered by phoneor face-to-face. Fees will dependon the type of service and whereit is delivered.

Your SLF GRS representative canprovide detailed informationabout these services includingthe qualifications of the advisors.

SLF CAP READINESS:Sun Life Financial has developedconsent language and obtains aCAP member’s consent whereneeded. For further informationon our Privacy Policy, please referto the Plan Sponsor Services website or www.sunlife.com.

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1. When an individual becomes eligible to enrol in a CAP, doyou clearly communicate the overall purpose of the plan andhow it operates, and specifically, the following information:

Contribution levels? Yes No

Investment options, including how to make and change them, and how long it will take for choices to be implemented? Yes No

Plan member responsibilities (as per Section 4.1.2 ofthe Guidelines) and right to access information? Yes No

The policy regarding failure to make investment choices? Yes No

Names of service provider(s) with whom CAP members interact? Yes No

2. Have you provided the following investment fund information to plan members:

The name of investment fund? Yes No

The names of all investment management companies responsible for the day-to-day management of fund assets? Yes No

The investment objective of the fund? Yes No

The types of investments held in the fund? Yes No

A description of risk associated with the fund? Yes No

Where and how members may get more information about fund holdings and other detailed disclosure about the fund? Yes No

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SLF CAP READINESS:SLF provides CAP members withdetailed and comprehensive planinformation through:• the Plan Member Welcome Kit

and through a number of otherpaper-based communications,

• face-to-face (enrolment meetings,information sessions), and

• the Plan Member Services website.

We have reinforced plan memberresponsibilities in online and customized communications.The new Enrolment Guide, whichwill be launched in 2006, willalso include information on planmember responsibilities. We alsoreinforce members' right toaccess plan information throughthe Plan Member Services website, plan member statementsand custom communications.

SLF CAP READINESS:Upon enrolment , Sun L i fe Financial provides plan memberswith a comprehensive package ofinformation that covers essentially allof the CAP Guidelines requirements.Our multi-media education andinformation program coupled with24/7 access to the Plan MemberServices website and to a thirdparty's detailed fund information,gives members ongoing access to updated information to makeinformed decisions.

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3. Is the information described in the previous questionavailable to CAP members for stock or guaranteed investment options?

Yes No Not Applicable

4. Have CAP members been given information about how to make transfers among investment options, including the following:

Forms required to effect transfers and where they must be sent? Yes No

Other ways of making transfers (e.g. Internet, IVR)? Yes No

Any costs for transferring among options? Yes No

Restrictions or limits on transfers (example: maximum limits after which a fee may apply)? Yes No

Circumstances, if any, in which transfer options may be suspended? Yes No

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SLF CAP READINESS:Information on other investmentoptions in the plan such as stockand guaranteed investments is available online through the PlanMember Services website.

SLF CAP READINESS:Sun Life Financial provides information on how to maketransfers among investmentoptions in the Plan MemberWelcome Kit provided at enrolment.Details of restrictions or limitson transfers are included in theplan booklet. Information wouldbe provided in advance wheretransfers are suspended due to a change of options, a change ofservice provider, or a change inour services.

Note: Sun Life Financial has a Short-TermTrading policy whereby plan members arecharged a 2% fee, payable to the fund,when they initiate an interfund transfer intoa fund followed by an interfund transfer outof the same fund within 30 calendar days.

This fee is not charged for transactions inguaranteed investments, directly held stockand money market funds, and does notapply to deposits on withdrawals, just interfund transfers.

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5. Have you provided CAP members with detailed informationabout all fees, expenses and penalties that are to be paidby them including:

Any costs that must be paid when investments are bought/sold? Yes No

Investment fund management fees? Yes No

Investment fund operating expenses? Yes No

Recordkeeping fees? Yes No

Any costs for transferring among investment options? Yes No

Account fees? Yes No

Fees for services provided by service providers? Yes No

Costs associated with accessing or using any of the investment information, decision-making tools or investment advice provided by the CAP sponsor. Yes No

6. Have you provided CAP members with an outline of how they can access additional information related to the plan and a description of the type of information that is available?

Yes No

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SLF CAP READINESS:Any transaction costs are detailedin the plan booklet provided in thePlan Member Welcome Kit. Thereare no costs to the plan memberfor accessing investment informationor decision making tools. The provision of investment advicewould be a program set up withthe plan sponsor – details of theprogram and any associated costswould be communicated to theplan members.

Segregated fund administrationexpenses are disclosed in theannual report available to sponsorsboth in paper and on the PlanSponsor Services website. We disclose plan member borne fees onthe Plan Member Services websiteand by December 31, 2005, we willinclude a Fee Summary Statementon plan member statements.

Note: Fees may be disclosed in aggregate,except where they are driven by a planmember’s decision (e.g. a withdrawal).

SLF CAP READINESS:SLF provides plan members with a comprehensive package of information at enrolment thatincludes detailed plan informationas well as information on how to access both plan and accountinformation on the Plan MemberServices website, through theAutomated Telephone System or the Customer Care Centre.

The plan member statement alsorefers members to the CustomerCare Centre and the Plan MemberServices website for additionalinformation.

Comments:

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1. How often do you provide statements to CAP members?

Annually Semi-annually Quarterly

Monthly Never

2. Can CAP members request a paper copy of their statementif it is provided in another format?

Yes No

3. Do plan member statements include all the informationrequired as stated in Section 5.1 in the CAP Guidelines?

Yes No

4. Do plan member statements include personal rate ofreturn for CAP members?

Yes No

Is the calculation and method for calculation of the personal rate ofreturn explained as per Section 5.1 of the CAP Guidelines?

Yes No

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SLF CAP READINESS:SLF issues member statements atleast annually.

SLF CAP READINESS: SLF issues plan member statements online and in print.

SLF CAP READINESS:Plan member statements currentlyinclude information appropriate toeach plan type. By December 31,2005, the plan member statementwill also include a Fee SummaryStatement as well as informationon how to obtain more details onfund performance and relevantbenchmarks.

SLF CAP READINESS:Plan member statements can show personal rates of return.They also refer plan members tothe Plan Member Services websitefor more details on their PersonalRate of Return (PROR).

By December 31, 2005, the statementwill explain the method used to calculate the Personal Rate of Return.

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5. Have you informed members that they may request additional information regarding their CAP accounts asstated in Section 5.2 .1 of the CAP Guidelines?

Yes No

6. How do you provide information to CAP members whenthere are significant changes to investment options (i .e.changes to the nature or operation of the option itself;the addition, substitution or removal of an option and anydeadlines, changes to member-paid fees or expenses;changes in service providers)?

Face-to-Face Electronically Print (newsletter/bulletin)

None All of the above

Does this information include all the required information as stated inSection 5.2.2 of the CAP Guidelines?

Yes No

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SLF CAP READINESS:SLF advises plan members oftheir right to request additionalinformation regarding their CAPaccount and the performance ofthe investment funds in theirplan through customized commu-nications and the plan memberstatement. We also reinforcetheir right to request additionalinformation in their EnrolmentGuide and on the Plan MemberServices website.

SLF CAP READINESS:SLF will work with plan sponsors toensure that when there is a changein investment options, plan membersreceive all of the information asrequired by the CAP Guidelines. If the change involves multipleinvestment options, you can workwith your Education Specialist to develop a comprehensive education strategy to ensure thatplan members fully understandtheir new investment options.

Other:

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available in the Enrolment Guide,through Morningstar Canada via thePlan Member Services website, andthe Customer Care Centre.

Morningstar Canada providesinvestment information for one,three, five and 10 year returns.The Plan Member Services website provides performance reporting forone-month, year-to-date, one yearand five year returns. Plan memberstatements show one month, year-to-date, one year and fiveyear rates of return.

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SLF CAP READINESS:7. How often do you provide performance reports to CAP members for investment funds?

Annually Semi-annually Quarterly

Monthly Never

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8. Do performance reports include the following information?

Name of the investment fund for which performance is being reported? Yes No

Benchmarking information? Yes No

Returns for corresponding benchmarks? Yes No

Performance over 1-, 3-, 5-, and 10-year periods? Yes No

Whether fees have been accounted in performance numbers? Yes No

Identification of method used to calculate fund return, and directions on where to find a more detailed explanation? Yes No

Explanation that past performance is no indication of future performance? Yes No

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SLF CAP READINESS:Information on fund performance isavailable in the Enrolment Guide,through Morningstar Canada via thePlan Member Services website, andthe Customer Care Centre.

Morningstar Canada providesinvestment information for one,three, five and 10 year returns.The Plan Member Services website provides performance reporting forone-month, year-to-date, one yearand five year returns. Plan memberstatements show one month, year-to-date, one year and fiveyear rates of return.

Morningstar Canada identifiesthe benchmark name, descriptionfor each fund and returns for eachbenchmark. Currently, the planmember statement shows aPersonal Rate of Return (PROR)and refers members to the PlanMember Services website for moredetails about the Personal Rate ofReturn. By December 31, 2005, wewill explain on the statement, themethod used to calculate the PROR.

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1. How often do you evaluate service providers against theoriginal criteria used to select them?

Annually Semi-annually Quarterly

Monthly Event-Triggered

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SLF CAP READINESS:We provide you with informationon our processes and performancethrough our Service StandardsReport Card, the CICA HandbookSection 5900 Audit Report (CICA Handbook Section 5970Audit Report beginning 2006)and the independent semi-annualISO 9001:2000 audit. We monitoryour satisfaction with our productsand services through our annualClient Loyalty and Member LoyaltyIndices. These reports and surveysgive you the information andinput needed to independentlyevaluate SLF’s performance. Inaddition, through our InvestmentManager Program (IMP), we alertyou of any known issues with theinvestment managers in the program.

Sun Life Financial may be onlyone of various suppliers you useto deliver a CAP. You will want to define how you evaluate eachof your suppliers independently.

Comments:

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2. How often do you review the investment options in the CAP?

Annually Semi-annually

Quarterly Monthly

What action do you take if there is unsatisfactory performance by aninvestment manager?

When deciding on what action to take, did you consider the factors identified in Section 6.3 of the CAP Guidelines?

Yes No

3. How do you monitor the quality of the CAP’s recordkeeping?

Review of complaints? Yes No

Periodic audits? Yes No

Annual review and certification? Yes No

Independent third party review? Yes No

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SLF CAP READINESS:Through our comprehensiveInvestment Manager Program(IMP), we offer a broad selectionof options as well as many of theessential aspects of plan oversight(investment manager selection,monitoring and review, communicationand pricing) in addition to detailedfund information via MorningstarCanada to support sponsor fundreview.

Sun Life Financial supports sponsors'decisions to make changes toinvestment options by commentingon timelines and ways to discontinuefund participation. In addition, we can work with the sponsor to provide communication for planmembers regarding the change in investment options.

SLF CAP READINESS:With third party audits such as the Annual Segregated FundAnnual Report, the CICA Handbook5900 Audit Report, and ISO9001:2000 certification, you canfeel confident in our recordkeepingeffectiveness. We also have developed a Service StandardsReport Card available on the PlanSponsor Services website thatmonitors our compliance withour stated service standards, whichcan assist you in monitoring thequality of the CAP recordkeeping.

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4. How often do you review the decision-making tools madeavailable to members to ensure they remain appropriateand that members are using them?

Annually Semi-annually

Quarterly Monthly

5. How often do you monitor the performance of serviceproviders who give your plan members investment advice*?

Annually Semi-annually Quarterly

Monthly Never

How do you monitor the performance of service providers who give yourplan members investment advice*?

Do you consider: Criteria used to select advisor?

Yes No

Complaints from plan members?

Yes No

* Note: The CAP Guidelines do not require sponsors to monitor the quality of advice provided toindividual plan members.

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SLF CAP READINESS:The tools provided by SLF on thePlan Member Services website andin the what? me save? Guide toSaving and Investing are designedto work for a broad range ofinvestors, regardless of their levelof investment sophistication andexpertise. We can also customizean overall education approach forplan sponsors. To analyze planmembers usage of the tools andother information available online,sponsors can access usage statisticreports available on the PlanSponsor Services website.

Early in 2006, we will launch newand improved decision-making tools.

SLF CAP READINESS:Sun Life Financial provides access to optional investment and financialplanning advice programs. Weperiodically review our adviceprograms to determine the levelof interest by plan sponsors andtheir members, and monitorfeedback from plan members.

Your GRS representative will discuss the level of service duringtheir regular update meetings, asnecessary. We fully investigateand address any issues with ourprogram as reported throughthese mediums.

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1. If your CAP is being terminated, are you providing the following information to plan members?

The options available to each plan member? Yes No

Any action(s) required to exercise these options? Yes No

Any deadlines for these actions? Yes No

The manner in which assets will be liquidated or distributed? Yes No

Any default option if they fail to exercise their options? Yes No

The impact termination of the plan will have on each investment option (e.g. tax consequences, market value adjustments, early withdrawal penalties, fees, etc.)? Yes No

2. If a CAP member leaves the plan (e.g. termination ofemployment, retirement, death), are you providing information about:

The options available? Yes No

Any action(s) required to exercise these options? Yes No

Any deadlines for these actions? Yes No

Any default option if they fail to exercise their options? Yes No

The impact that termination of plan membership will have on each investment option (e.g. tax consequences, market value adjustments, early withdrawal penalties, fees, etc.)? Yes No

Note: In the event that a CAP member dies and ceases to participate in the plan, this informationshould be provided to the member’s designated beneficiary or personal representative.

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SLF CAP READINESS:SLF follows a defined and structuredprocess, in accordance with relevantlegislation, for communicatingthe required information upontermination of a plan.

SLF provides terminating planmembers with a complete pack-age of information regardingtheir options.

SLF CAP READINESS:SLF follows a defined and structuredprocess, in accordance with relevantlegislation, for communicatingthe required information when a member leaves the plan.

SLF provides terminating planmembers with a complete packageof information regarding theiroptions.

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NO

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