Our submissions reflect three of our sections: the privacy law section, the pension and benefits law section, and the constitutional law section. The constitutional law section raises serious reservations regarding the bill's constitutionality. Again, that's one of the reasons the CBA has said that the bill should not be passed.
With respect to privacy concerns and pension concerns, we believe there are fundamental issues there. If the bill does proceed, it is the pension law section's view that pensions and employee benefits should be excluded from the bill—not simply that benefit payments not be made public, but that they not be required to be reported and that they not be required to be posted on a website.
I don't think the intent of the bill, at least on its face, was ever meant to capture pension and employee benefits, training funds, and supplementary unemployment benefit plans, the other types of plans that are covered by section 6 of the tax act. We believe that those should be exempted outright from the coverage of the bill.