CFUW Ontario Council Response To the. Consultations on the Ontario Retirement Pension Plan
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1 CFUW Ontario Council Response To the Consultations on the Ontario Retirement Pension Plan February 2015 Submitted by Brenda Robertson President, Ontario Council Canadian Federation of University Women
2 Consultations on the Ontario Retirement Pension Plan Proposal CFUW Ontario Council is composed of 54 clubs within Ontario, comprised of members living In urban and rural areas across Ontario. We are non-partisan, nonsectarian, a voluntary, self-funded, nongovernmental organization. Our members are active in public affairs, advocating on public education, justice, health and environmental issues as well as the status of women and human rights. Ontario Council is part of the Canadian Federation of University Women which is the largest affiliate of the International Federation of University Women. Ontario Council of the Canadian Federation of University Women welcomes the provincial government s initiative to create an Ontario Retirement Pension Plan. Discussion Questions Issue #1 Definition of comparable Workplace Pension Plan DISCUSSION QUESTIONS 1. The government s preferred approach remains a CPP enhancement. Therefore, the definition of comparable should be determined with a view to maintaining the potential for integration with the CPP in the future. With this in mind, should the definition of a comparable workplace pension plan mirror the key features of the CPP and ORPP? Yes, a comparable workplace pension plan should mirror the key features of the CPP and ORPP. 2. Which features of the CPP and the ORPP would be the most important to capture in a comparable plan? a. For example, how important is protection against longevity risk in a mandatory retirement savings vehicle? b. Similarly, how important is protection against investment risk in a mandatory retirement savings vehicle? Both Longevity risk and protection against investment risk are important and should be part of the comparable plan. Indexing to inflation needs to be included. The capital in the pension funds must also be locked in so that neither employee nor employer has access to the fund for any purpose other than that of payment of retirement benefits. 3. Are there circumstances under which other retirement savings vehicles such as DC plans should be considered comparable? a. For example, would establishing a minimum employee/employer contribution rate (that would provide for a similar benefit to the ORPP) for DC plans help make DC plans comparable? Due to the nature of the DC plans, even if minimum contribution rates are established, they will remain unprotected from investment, do not adjust benefits to inflation, and have a longevity risk. However, employees in big companies without pension plans may receive funds and be expected to self-manage retirement savings plans (DC). Employees who do this may wish to risk the market variations rather than risk the company going bankrupt and seeing their pension plans disappear entirely as has happened in the past.
3 b. Similarly, would requiring members to convert a portion of savings in a DC plan to an annuity upon retirement help make DC plans comparable? If so, would Ontario s insurance industry have the capacity to offer affordable annuities on this scale? Annuity option not widely used. Negotiations with the Insurance Industry would be needed and may take too long to provide this option in the ORPP. 4. Employers may have multiple and complex retirement savings arrangements. a. How would employers currently offering non-comparable plans expect their plans to work alongside the ORPP? Mirroring the framework of deductions/contributions required for CPP would provide employers a model which is already familiar. b. How much time would employers need to take stock of their current approaches and make decisions about the right compensation mix going forward? A graduated schedule could be set giving time to investigate approaches, compensation mix, and prepare for transition. 5. In your view, what would be the best definition of comparable workplace pension plans? A predictable stream of retirement income fully secured, paid for life, indexed, funded through contributions by employee and employer. Issue #2 The Right Minimum Earnings Threshold DISCUSSION QUESTIONS 1. Does mirroring the CPP minimum earnings threshold strike the appropriate balance between contributing and accruing benefits? Yes, ORPP should mirror CPP with the minimum earnings threshold of $3500. It is advantageous to have the same minimum earnings threshold as CPP. Mirroring will streamline pension management bureaucracy and ensure ease of portability should ORPP be blended into CPP at some time. Also this could be a standard should other Provinces/Territories develop a similar pension plan which means transferring to another provincial plan would be facilitated. 5. Are there other ways that Ontario could help address concerns about the ability of persistently low-income workers to contribute and accumulate benefits? Ontario needs to promote Financial Literacy programs, adult education programs for upgrading, and increase spaces for child care. Poverty Reduction Strategies need to be implemented and extended. Any clawback of benefits for those below the low income threshold should be eliminated.
4 6. Should Pillar 1 supports, including the GIS and GAINS, be changed so that future low-income seniors do not experience reduced benefits as a result of higher ORPP benefits? Contributing to ORPP gives the senior an increased income with 95 %, whereas the GIS and CPP replaces only 85% if there was no ORPP. A mechanism should be put in place so that clawbacks would not negatively affect those identified as in a low income measurement. Issue #3 Addressing the Needs of the Self-Employed DISCUSSION QUESTIONS: 1. Self-employed individuals will not be able to participate in the ORPP, given the current rules under the federal Income Tax Act (ITA). Should Ontario engage in discussions with the Government of Canada to amend the ITA rules in order to allow the self-employed participate in the ORPP? Self-employed individuals in Ontario need to be consulted to determine their interest in participating in the ORPP. There needs to be some differentiation when government talks about self-employed between higher income earners who are working from a stable, wellfinanced base and those who are operating for example, small farms and very small businesses. There should be a change to provisions through the Income Tax Act to make it possible for self-employed to contribute to ORPP. Discussion in this effort with the Government of Canada is supported. 2. What more can be done with regards to improving financial literacy among the self-employed? What role can the financial services sector play in educating the self-employed? Promote Financial Literacy programmes through agencies such as the Small Business Enterprise Centres (SBEC) and the Ontario Farmers Association (OFA); provide training and referral information to the managers and community leaders, to ensure services are available to assist the self-employed in their business plans, and strategic planning long term. 3. How else could the government assist self-employed individuals in achieving a secure retirement future? Ensure information is made available on retirement planning through government agencies and sectoral associations. Financial Institutions may reach a certain population of the selfempoyed (higher earners), but may not reach others such as domestic workers, people working out of their homes, workers who do piece work in their homes. Many of these will be women, and would be better reached through social services.
5 #4 Other comments/questions for the provincial government Questions: 1. What are the guidelines for Temporary Foreign Workers and their employers for contributing to the ORPP and what provisions are there for TFWs to access their contributions if they return home before retirement age? 2. What model for administration would be followed to be efficient and cost effective? 3. What technological means would be used that would be efficient and cost effective? 4. What would happen if the arms length agency for administrating the ORPP did not invest wisely and sufficient funds were not available to pay retirees? 5. What oversight would be in place? Concerns: Employers who provide benefit plans, but exclude workers once they reach a certain age, usually 65 Retirement ages range from 55 to 65. But that age is rising. In 2012, the Government of Canada raised the age at which Canadians can claim OAS from 65 to 67. This has significant impact on older Canadians. Even if the employee continues to work past 65, they do not receive benefits from their employer as the employer is not mandated to provide benefit programs for their employees. As a result these older employees are no longer entitled to medical, dental, ocular or other employee group benefits-only to those benefits mandated or managed by the federal government or the crown. This is true regardless of how much or how long they have contributed to their employersponsored benefit plans. And: The Ontario Employment Standards Act limits participation in benefit plans to employees who are 18 or over but under 65 (Ontario Ministry of Labour, 2014) This Ontario Employment Standards Act (Ontario Ministry of Labour, 2000) declares that every individual is equal before and under the law, has the right to protection and shall not be discriminated against including discrimination based on age. The limiting of participation in benefits based on age needs to be addressed, at the least to bring it in line with the new Federal law limiting access to OAS to 67 years.
6 CFUW Ontario Council recognizes the need for the enhancement of benefits within Pillar 2. As defined in the Ontario Retirement Pension Plan: Key Design questions. This is of particular importance as a result of the federal government s lack of support for an enhancement of CPP to better provide for retired Canadians. Not all retirees have the benefit of Pillar 3 income as a result of where they have worked and/or lack of sufficient savings. Our workforce today is more mobile than ever and many young people begin their careers much later than the previous generation. At minimum, we would expect the ORPP to be comparable to the CPP providing defined benefits, an income for life, indexed to inflation, with pooled investment risk. Ontario Council CFUW recognizes that ORPP is a provincially sponsored CPP enhancement to ensure that the average Canadian has a basic income living wage when retired. Ontario Council CFUW would like to thank the provincial government for this opportunity to participate in these consultations. Sincerely Brenda Robertson President Ontario Council Canadian Federation of University Women president@cfuwontcouncil.ca brenda.r@sympatico.ca
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