Thank you very much.
CARP is a national, non-partisan organization with more than 300,000 members and 50 chapters across the country. We advocate for policy and legislative changes that will improve the quality of life for all Canadians as we age, and retirement security is the issue that brings us here today.
The core goal of any country's pension system is to provide an adequate system that is available to the full breadth of the population, sufficient to prevent poverty in old age, affordable to employers and employees, and robust enough to withstand major shocks, including economic, demographic, and political volatility. Recent events demonstrate that Canada's retirement system is not meeting that goal, in part because of inadequate pension coverage.
The question is whether the pooled registered pension plan envisioned by Bill C-25 fulfills the goal of a robust system.
It is not universal, but is optional. It's at the employer's option.
It's not necessarily low-cost. We have already heard the Minister of State for finance indicating that they may not set fees according to section 26 of the act.
It is a strictly defined contribution plan, which is little different from a group RRSP and not as attractive in some cases, since this plan is going to be locked in. And it is not as portable as it could be, given the challenges of the bureaucratic changes.
So it is respectfully submitted that material improvements are necessary, including proceeding with the promised enhancement of the CPP in order to ensure that the vast majority of Canadians can actually have access to an affordable and reliable pension savings vehicle to save for their own retirement.
To speak specifically first on the issue of universality, the PRPPs are dependent on the voluntary choice of employers to enrol their employees, and once enrolled the employees have an option to opt out. If they are not enrolling in RRSPs now, then what are the improved incentives going to be that will have employees choose to remain within PRPPs? Certainly deductible contributions are welcome, but mandatory employer contributions would be even more welcome. Even the existing DC plans require a 1% payroll contribution by the employer in order to be registered.
We would suggest that some reconsideration be made of the locking-in provision, because at this point, for many people it's a disincentive. It is important to allow some flexibility to employees, because they are now, according to the scheme of the act, not able to change their own administrator once an employer makes that change.
Auto-enrollment is something we have recommended, because it would improve uptake. But it's only beneficial if the plan itself is providing a predictable and adequate pension; it's not necessarily valuable if it is driven into the arms of a private-sector plan.
The second point that's important is that any new plan should enhance the adequacy of any retirement income, in terms of both sufficiency and predictability. The pooling and professional management envisioned by the PRPPs will of course improve adequacy, but high fees can still erode the earnings, as evidenced by the Australian experience with its superannuation fund. We are concerned with the reported comments that the government will not use section 26 to regulate the fees but will rather let it go to competition among relatively few players.
Finally, defined contribution plans leave the risk with the employees.
We are also a little bit concerned about the governance and fiduciary responsibilities, which at first seem to impose a fiduciary obligation, but we find that as soon as an employee makes a choice, this is going to be relieved.
I want to make a final comment on the CPP enhancement.
I left with the clerk, Mr. Chair, a copy of a chart that I think the members might find useful and, if it's acceptable to you, I'd ask that it be circulated.
The point I want to make about CPP enhancements simply is that it is an opportunity to provide for a mandatory contributory plan. CARP members were very encouraged in June 2010 when the finance ministers offered both a CPP enhancement and the PRPPs. Now that the CPP enhancement is off the table, that is a concern.
Our point to you simply is that even a modest improvement in the CPP—say, a 10% improvement to the benefit—would be a very cost-effective method to improve on people's retirement security. The cost is no more than $45 a month for employer and employee at the maximum levels, and for a low-income person—for whom this matters the most—at, say, a $20,000 income, the cost is an additional $18 a month for employer and employee.
We believe that Bill C-25 is mostly an important first step in addressing the retirement savings gap among Canadians, but we believe more can be done.