Employee Future Benefits – Use of a Funding Valuation

The AcSB continued discussing feedback received on its Exposure Draft “Employee Future Benefits – Use of a Funding Valuation”. The Board discussed comments on the draft of the amendments to Section 3462, Employee Future Benefits, and the Basis for Conclusions. The Board will review the final draft of the amendments and Basis for Conclusions at an upcoming meeting in July 2020.

The AcSB had originally proposed an effective date for the amendments of January 1, 2021. In light of COVID-19 developments, the Board decided to change the effective date to years beginning on or after January 1, 2022. Early adoption of these amendments will be permitted.

The AcSB discussed feedback on its Exposure Draft, “Employee Future Benefits – Use of a Funding Valuation,” through comment letters and roundtable consultations with stakeholders. The Board also considered recommendations from its Private Enterprise Advisory Committee. The Board decided to add an example of what would be included in the defined benefit obligation and retain the word “solvency” in Employee Future Benefits, paragraph 3462.029D.

The Board directed staff to conduct targeted outreach to finalize the inclusion of all components of a funding valuation for legislative, regulatory or contractual purposes in the calculation of the defined benefit obligation.

The AcSB plans to review a draft of the final amendments to Section 3462 at its May 2020 meeting.

The Committee considered stakeholder feedback on the AcSB’s Exposure Draft, “Employee Future Benefits – Use of a Funding Valuation.” Committee members:

• provided input on staff’s proposed example to clarify the requirement to include all components of a funding valuation for legislative, regulatory or contractual purposes in the measurement of the defined benefit obligation;
• advised the Board to retain the word “solvency” in Employee Future Benefits, paragraph 3462.029D; and
• recommended changes to the Basis for Conclusions document and the transition provisions.

The AcSB will deliberate the Committee’s feedback at its March 2020 meeting.

The AcSB considered feedback received from its Private Enterprise Advisory Committee and through outreach with actuaries on a draft of the proposals relating to the use of a funding valuation to measure the defined benefit obligation for defined benefit plans with a funding valuation requirement. The Board agreed that the defined benefit obligation should be measured at the amount that is required to be funded in accordance with legislative, regulatory, or contractual requirements.

The AcSB also discussed a draft of the proposals relating to the use of a funding valuation to measure the defined benefit obligation for defined benefit plans for which there is no legislative, regulatory, or contractual requirement to prepare a funding valuation.

For these defined benefit plans, the Board reconsidered the accounting policy choice in paragraph 3462.029C to measure the defined benefit obligation using an accounting valuation or a funding valuation. The Board understands that this accommodation to allow the use of a funding valuation for these defined benefit plans is causing diversity in practice. As a result, the Board tentatively agreed to remove this accommodation and plans to expose this proposed removal in the forthcoming exposure draft.

The AcSB also considered the transitional provisions for the proposed amendments and confirmed that transitional relief should be provided.

The AcSB plans to issue the exposure draft no later than the third quarter of 2019.

At its recent meeting, the Committee discussed a number of topics including employee future benefits, amendments to other frameworks, and much more.

The AcSB continued its discussion regarding changes to pension legislation in Ontario and Quebec and the effects on the measurement of the defined benefit obligation for registered defined benefit plans when an enterprise elects to use a funding valuation in accordance with Section 3462, Employee Future Benefits.

The AcSB plans to issue an exposure draft to clarify that all components of a going concern funding valuation required for legislative or regulatory purposes be included in the measurement of the defined benefit obligation when the funding valuation is chosen. The Board agreed that it would not refer to specific legislation so that the amended guidance would address current and future legislation.

The AcSB also considered the use of the funding valuation for defined benefit plans for which there is no legislative, regulatory, or contractual requirement to prepare a funding valuation. Specifically, the Board discussed the meaning of “on a basis consistent with” in paragraph 3462.029C. The Board reviewed the work done when Section 3462 was developed and determined that the intent was that “on a basis consistent with” is equivalent to “the same”. The Board decided to clarify the guidance relating to this issue in the exposure draft.

The AcSB directed staff to consult with actuaries on a preliminary draft of the proposed amendments relating to these issues.

The AcSB also considered the transitional provisions for the proposed amendments and decided that transitional relief should be provided.

The AcSB plans to discuss this topic further at its June 2019 meeting, including considering the feedback received from consultations with its Private Enterprise Advisory Committee as well as actuaries.

The AcSB plans to issue the exposure draft no later than the third quarter of 2019.

Quebec Stabilization Provision

The AcSB continued its discussion regarding changes to pension legislation. The Board considered the use of a funding valuation for registered defined benefit plans in Quebec, which includes the Stabilization Provision as established in 2016 by Quebec’s pension regulator for private sector plans. The Board is concerned with the diversity arising in practice as to whether the Stabilization Provision is included in the measurement of the defined benefit obligation when an enterprise elects to use a funding valuation in accordance with Section 3462, Employee Future Benefits. The Board was advised that the diversity arises from the view of some stakeholders that the inclusion of the Stabilization Provision results in a measurement akin to a solvency valuation.

The AcSB decided to undertake standard-setting action by developing an exposure draft to propose changes to Section 3462 to clarify its intent that the Stabilization Provision should be included in the measurement of the defined benefit obligation when the funding valuation is chosen. Given the reported diversity in practice, the Board will also consider transitional provisions in developing its exposure draft.

The Board plans to issue the exposure draft no later than the third quarter of 2019.

Defined benefit plans without a funding valuation requirement

The AcSB considered the use of the funding valuation for defined benefit plans for which there is no legislative, regulatory, or contractual requirement to prepare a funding valuation. An example of such a plan is an unfunded defined benefit supplemental executive retirement plan offering pension benefits. The Board is concerned with the diversity arising in practice as to whether an assumed Provision for Adverse Deviation (PfAD) based on that required by Ontario’s pension regulator and the Quebec Stabilization Provision should be included in the measurement of the defined benefit obligation when an enterprise elects to use a funding valuation for these defined benefit plans.

The AcSB discussed the meaning of “on a basis consistent with” in paragraph 3462.029C. The Board’s intent was that “on a basis consistent with” is equivalent to “the same”. Accordingly, the Board agreed that the PfAD and Stabilization Provision should be included in the measurement of the defined benefit obligation for these defined benefit plans. The Board also noted that allowing the use of a funding valuation was an accommodation that eliminated the additional costs of preparing a separate accounting valuation, which would otherwise be required.

The AcSB understands that some enterprises, consistent with their approach for funded defined benefit plans, did not include the relevant provision in the measurement of the defined benefit obligation for unfunded defined benefit plans. Accordingly, the Board will consider including this issue, along with any transitional provisions, in developing the exposure draft on the first issue under “Quebec Stabilization Provision.”