Yes, in every letter. It's a cost for everybody.
The Bill proposes to require disclosure of personal information (including personal health and medical information) which conflicts with legislation already in place. Further, the Bill proposes to duplicate existing financial disclosure requirements applicable to pension and benefit trusts.
On the website for Bill C-377, Mr. Hiebert states that through the operation of the Bill, the Canadian public “will be empowered to gauge the effectiveness, financial integrity and health of Canada’s unions”, and that the purpose of the bill is “to increase transparency and accountability” of labour unions. Just as we noted in our previous letter about Bill C-317, we believe that Bill C-377 goes well beyond Mr. Hiebert’s stated intentions. We are writing to again urge all members of the House of Commons to consider the consequences the Bill will have for multi-employer pension and benefit plans.
In its present form, Bill C-377 would mandate certain disclosure from “labour organizations” and “labour trusts”, as defined. The definition provided for “labour trust” includes “a trust or fund...that is established or maintained in whole or in part for the benefit of a labour organization, its members, or the persons it represents.” ...
We believe that there are several reasons why it would not be appropriate for this Bill to become law due to serious flaws, exemplified by its treatment of pension and benefit plans under the proposals in Bill C-377.
Pension and benefit plans are already subject to extensive disclosure requirements under other provincial and federal legislation. For example, s. 93 of Ontario’s Labour Relations Act, 1995, requires the administrator of a plan that benefits union members to file an annual statement with Minister of Labour setting out various aspects of plan finances. The legislation also requires that a copy of that statement be provided, at no cost, to any union member that makes such a request. Similar disclosure requirements are created by Ontario’s Pension Benefits Act and under sections 12 and 13 of the Federal Pension Benefits Standards Act. A variety of other statutes in Canada impose similar requirements, and moreover, pension and benefit plans are already required to file annual statements with the Canada Revenue Agency. In addition, trustees of pension and benefit plans are subject to stringent fiduciary duties at common law that obligate them to act solely in the best interests of the plan and its beneficiaries. Similar duties arise under pension benefits legislation. Bill C-377 will create additional and unnecessary red tape for a sector that is already in a difficult state.