Thank you, Mr. Chair and gentlemen.
My name is Shirley-Ann George. I'm the senior vice-president of policy at the Canadian Chamber of Commerce. With me today is Mr. Serge Pharand, vice-president and corporate comptroller at Canadian National.
It gives us great pleasure to be before the House of Commons Standing Committee on Finance to present the views of the Canadian Chamber of Commerce and our members on this important issue. As many of you know, the Canadian Chamber of Commerce is the largest business organization in Canada, with membership of 175,000 small to large businesses from all sectors of the economy and all regions of this country. We pride ourselves on being the voice of Canadian business, and we work hard to ensure Canada's business community is able to maximize its economic and social contribution to all our well-being.
We commend the finance committee for consulting with Canadians on the most appropriate means to strengthen Canada's pension plan. Today, I will focus my remarks on the voluntary pension system—the defined benefit, or DB, and defined contribution, or DC, pension plans.
The unprecedented decline in global equity markets and long-term interest rates has significantly reduced the funded status of DB pension plans. According to Watson Wyatt, the ratio of plan assets to plan liabilities—that is the solvency ratio—of the typical pension plan fell from approximately 95% in 2007 to 69% at the end of 2008.
Many companies with DB pension plans are required to make substantially higher pension contributions to offset the substantial pension losses. This requirement is taking effect during a recession when they can least afford it. As a result of these large special payments, companies are diverting available funds from productivity and growth-enhancing capital investments. Their competitiveness and that of our nation is undermined. Reduced capital spending puts the economy at risk of a longer and deeper recession.
For many companies, these increased costs may force layoffs and compel reductions in employee compensation and/or increases in employee contributions. In some cases, it may even force companies into bankruptcy. The real proof of the seriousness of the situation is the level of concern expressed by plan sponsors. According to a Watson Wyatt survey, 88% of senior Canadian executives believe defined benefit plans are in a widespread funding crisis.
In early April, the federal government released proposed regulations to provide temporary solvency funding relief for federally regulated DB plans. One option was to allow the sponsor to extend the solvency funding period by one year. Another option was to allow a plan sponsor to extend the solvency payment schedule from five to ten years, provided no more than one-third of both plan members and retirees object. If consent is not obtained, the difference between the five-year and ten-year payment schedule would need to be secured by a letter of credit.
Our members expect that obtaining the consent of employees and retirees at this time will be difficult. In particular, the requirement for retiree consent may preclude access to funding relief for the very employers and plan sponsors who most need the relief. In our view, the option to extend the amortization period should not be conditional on consent.
Our members agree that the five-year solvency deficit amortization period imposes onerous and volatile cash demands on companies. It should be extended to at least 10 years and applied consistently to all companies to allow businesses to spread their solvency payments over a longer period, freeing resources for today's operations.
Plan sponsors should be able to either use a letter of credit or place funds in a trust separate from pension funds in lieu of solvency contributions. If utilized, such instruments would provide the same security to plan sponsors as cash contributions to the pension fund and should be recognized as a pension asset in solvency valuations.
With credit markets remaining tight, it is difficult for many companies to obtain a letter of credit or secure one at a reasonable price. If used, letters of credit and funds in trust should be released if the pension returns to a fully funded position.
We strongly urge the government to move quickly to provide the funding relief many employers urgently need.
I also have some recommendations that would benefit the employees. Employers should provide affected plan members with notice of any changes, greater clarity and understanding of the issues, and full disclosure of the funding status. Employee concerns should be alleviated by making it clear to employers that they should not be able to terminate a plan and continue in business without funding benefits, and there should be no partial termination.
To add transparency to this whole process, we recommend that annual valuations be required. When compared to the existing rules, our 10-year amortization proposal, combined with the requirement to file annual valuations, can result in more security for the members of a plan and achieve the goal of reducing volatility for the sponsors. We urge the committee to take a long-term view when assessing our proposal.
I also have some comments on needed changes to the defined contribution RRSP and RRIF programs and recommendations that might be considered alongside the Rotman proposal, but given the shortage of time, I hope one of you will ask questions on that during questions and answers.