COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION …ppp.ia.ca/pdf/PPP-Setup-Process.pdf ·...

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. INVESTED IN YOU. ia.ca 1. Member Profile Form 2. PPP Proposal 3. Request for T4 slips 4. Information Form 5. Completing the Onboarding Documents 6. Plan Registration 7. Your Binder 8. iA Financial Group Client Space Activation Letter 9. CRA Deemed-Registration Letter 10. FSCO Deemed-Registration Letter 11. CRA Final Registration Letter 12. Employer Contributions 13. Member Qualifying Transfer 14. FSCO Formal Registration Letter 15. FSCO Pension Services Portal (PSP) Activation Letter 16. Delegating iA on FSCO’s PSP 17. CRA Re-Assessment (Notice of Assessment) 18. Ongoing Compliance

Transcript of COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION …ppp.ia.ca/pdf/PPP-Setup-Process.pdf ·...

Page 1: COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION …ppp.ia.ca/pdf/PPP-Setup-Process.pdf · COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS ... much more money and increases

COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc.

INVESTED IN YOU.

ia.ca

1. Member Profile Form

2. PPP Proposal

3. Request for T4 slips

4. Information Form

5. Completing the Onboarding Documents

6. Plan Registration

7. Your Binder

8. iA Financial Group Client Space Activation Letter

9. CRA Deemed-Registration Letter

10. FSCO Deemed-Registration Letter

11. CRA Final Registration Letter

12. Employer Contributions

13. Member Qualifying Transfer

14. FSCO Formal Registration Letter

15. FSCO Pension Services Portal (PSP) Activation Letter

16. Delegating iA on FSCO’s PSP

17. CRA Re-Assessment (Notice of Assessment)

18. Ongoing Compliance

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

1. Member Profile Form You have heard about the Personal Pension Plan (PPP) from your advisor or visited our PPP website and now wonder if this plan is a tax-effective solution for you. We suggest to prepare a PPP Proposal personalized to your own situation. You need to complete the Member Profile Form. Specifically, we need your date of birth, the full name of your company, your T4 earnings since your date of employment, your RRSP assets and your unused RRSP room. Figures don’t need to be exact at that point, but the more they are the more accurate the PPP Proposal will be. 2. PPP Proposal The PPP Proposal describes the advantages of the PPP over a personal RRSP and shows a personalized projection under both options according to the financial information provided. It also projects the pension offered by the PPP at different retirement ages and shows the various options available at retirement. It is possible to contact your relationship manager at INTEGRIS to organize a conference call or webinar to walk the member, the advisor and the accountant through the results.

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

3. Request for T4 slips One of the numerous advantages of the PPP is that it allows the member to recognize years of past services earned while working for the company when no pension plan existed. It allows one to tax-shelter much more money and increases the benefits payable at retirement. To ensure our calculations will be accurate and avoid any potential issues with the regulators, we require copies of T4 slips for all years of past services that are to be recognized by the plan. We know how difficult it can be to retrieve T4 slips from previous years and offer to request them to the Canada Revenue Agency (CRA) on your behalf using a CRA Form T1013. This request can sometime take as much as 4 months. For this reason, although you may not be ready to establish the PPP just yet, we recommend that we start the process of gathering the T4 slips for past years right away to avoid undue delays when you will be ready to go ahead with the PPP.

4. Information Form Once you are satisfied with the tax savings the PPP can help you achieve, your relationship manager will supply you with an Information Form designed to capture key data that will be required to prepare the plan’s Onboarding Documentation. Please return it to your relationship manager at INTEGRIS with all supporting documents: (1) articles of incorporation (2)most recent notice of assessment from the CRA (3) latest RRSP statement as at January 1 of the current year.

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

5. Completing the Onboarding Documents With the information provided in the Information Form, INTEGRIS Compliance will send you a package of documents you need to complete prior to establishing the PPP. These documents include the Plan Provisions, the Insurance Contract, some forms gathering your personal information and some forms required by the regulators. A Checklist of all the Onboarding Documents will also be provided. Once completed and signed, all original documents must be mailed to : Chief Compliance Officer INTEGRIS Pension Management Corp 940 The East Mall, Suite 110 Toronto ON M9B 6J7 We recommend that scanned versions of the documents be emailed to [email protected] prior to sending the signed documents by courier so that corrective actions may take place right away. 6. Plan Registration INTEGRIS and iA Financial Group will coordinate together to verify your information and prepare the actuarial valuation report and all other necessary documents for registration. The plan will be registered with the CRA and the Financial Services Commission of Ontario (FSCO). Once we have received all the documents and information, we target to send the documents to the regulators within 2 weeks.

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

7. Your Binder At the same time we register the plan with the regulators, we will prepare a Binder containing all the documents related to the administration of the pension plan. We will mail you this Binder and email it to your financial advisor to review it with you. The Binder contains: The Contract with iA Financial Group The Agency Agreement with INTEGRIS The Plan Text of the PPP The Administrator’s Guide The initial Actuarial Valuation Report The Contribution Statement A CD with an Excel Spreadsheet re: contributions The Statement of Investment Policies and Procedures (SIP&P) The Procedure to Delegate on FSCO’s Pension Services Portal (PSP) An Invoice by iA Financial Group 8. iA Client Space Activation Letter You will receive a letter from iA Financial Group giving you your Client Space access code which will enable contributions made to the PPP to be allocated within the various segregated fund options available on the PPP platform (and GICs).

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

9. CRA Deemed-Registration Letter Typically within 20 days of receipt of the Onboarding Documents, you will receive a letter from the CRA notifying you that they have received the documents from iA Financial Group and will be reviewing the file. This letter also provides the registration number that they has been assigned to the PPP. Please note that the plan has not received final approval of the registration at this point. There is no need to send INTEGRIS or iA Financial Group a copy of this deemed registration letter since the CRA will have notified us at the same time. 10. FSCO Deemed-Registration Letter FSCO will also send you a letter informing you that the submission for registration will be processed shortly. FSCO assigns the same registration number that CRA assigned. As with CRA’s letter, this letter is not the final approval of the registration with FSCO. There is no need to send INTEGRIS or iA Financial Group a copy of this deemed registration letter since FSCO will have notified us at the same time.

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

11. CRA Final Registration Letter CRA will then send you another letter about three months after the deemed registration letter to advise that the registration of the PPP has been confirmed. They usually approve the initial actuarial valuation report at the same time as well. Your plan is now fully registered with CRA and you can now start contributing to the plan including transferring RRSP assets as a qualifying transfer to buy back past service, and making corporate contributions (if any) required to complete the past service purchase. There is no need to send INTEGRIS or iA Financial Group a copy of this deemed registration letter since the CRA will have notified us at the same time. 12. Employer Contributions The company can now fund the past service deficit if any and the normal cost of the plan. We have included a Contribution Statement in the binder you received and a CD with an Excel Spreadsheet. Given the complexity of calculating the contributions in some PPPs, we recommend that you use the Excel Spreadsheet to calculate the amounts that the company can contribute to the plan. You may then send a cheque payable to iA Financial Group to the following address with a printout of the Excel Spreadsheet to clearly identify your plan. iA Financial Group Group Savings and Retirement (CSC6224) P.O. Box 1907, Station Terminus Quebec City, Quebec G1K 7M3

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

13. Member Qualifying Transfer If you are buying back past service in the PPP, you are most likely required to do a Qualifying Transfer. The Qualifying Transfer is required by CRA to ensure a certain level of fairness in the Canadian retirement system between an individual with a PPP versus someone who doesn’t have one. It consists of transferring some assets held in a designated savings arrangement (RRSPs, LIRAs, RRIFs, LIFs, and DC plans) to finance a portion of the past services recognized in the PPP and the remainder of the costs is funded by the company. The amount of Qualifying Transfer that must be transferred is indicated on the Contribution Statement included in the binder. Your financial advisor should use CRA Form T2033 for RRSPs and T2151 for DC Plans. Please note that the Qualifying Transfer must be completed within 90 days following the date on CRA’s final registration letter. Once the transfer is completed, your advisor must provide iA Financial Group with copies of the statements showing that the transferred assets came from a designated savings arrangement to the PPP because it will be required by the CRA as part of the internal audit process. 14. FSCO Formal Registration Letter FSCO will also send you a registration letter after they have reviewed all the documents submitted. It is usually three to six months after submission of the registration documents. The FSCO Formal Registration Letter also includes a Certificate of Registration. There is no need to send INTEGRIS or iA Financial Group a copy of this deemed registration letter since FSCO will have notified us at the same time.

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

15. FSCO Pension Services Portal (PSP) Activation

Letter Following their formal registration letter, FSCO will mail the plan administrator’s contact person another letter containing an activation key to create your account on the PSP. It is important that you activate this access upon reception of their letter and then delegate iA Financial Group’s actuaries on the PSP to access your account. See instructions re: PSP below. 16. Delegating iA on FSCO’s PSP INTEGRIS and iA Financial Group provides you with a full service PPP product that ensures all required filings can be effected seamlessly Some of the filings have to be submitted through FSCO’s PSP and the only way to do so is for us to be delegated on your PPP account. It is therefore important that you activate your account and then follow the procedure that we have included in the binder to delegate iA Financial Group’s actuaries on the PSP. Once this delegation has taken place, iA Financial Group can then make all necessary filings with respect to the PPP on a go-forward basis, thus simplifying administration for you.

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COMPLIANCE MANUAL FOR ONTARIO REGISTERED PENSION PLANS

iA Financial Group is a business name and trademark of Industrial Alliance Insurance and Financial Services Inc. ia.ca

INVESTED IN YOU.

17. CRA Re-Assessment (Notice of Assessment) When we establish a PPP for you, CRA may reduce your RRSP contribution room depending on whether you are a connected person to the company and if past service is being recognized under the PPP. At the time of submitting the registration documents to CRA, we will complete a CRA Form T1004 - Applying For The Certification Of A Provisional PSPA if the PPP is recognizing past service and a CRA Form T1007 - Connected Person Information Return if you are a connected person. After processing these forms, CRA will send you a re-assessment of the RRSP Deduction Limit. It is important to wait for this Notice of Assessment before you attempt to contribute to your RRSP following the establishment of the PPP. We recommend that you send us a copy of this Notice of Assessment to confirm all forms have been processed correctly. 18. Ongoing Compliance With the PPP now established and registered and with ongoing contributions being made to the plan and invested by the financial advisor, please refer to the Compliance Manual for Ongoing Adminstration for a calendar of compliance events that punctuate the year once the plan is in effect.