Registered Plans Directorate Newsletter, no. 95-2
May 4, 1995

Registered Plans Division Services

Introduction

We, at Revenue Canada, have written this newsletter to provide a brief overview of our services for registered deferred income plans, including the service delivery standards for several individual services. We developed the standards through internal monitoring of turnaround times and through client consultation. The standards indicate our response time for a given service. Our constant goal is to improve these times based on the available resources.

We formed the Registered Plans Division (RPD) to administer the Income Tax Act, Regulations, and administrative rules relating to the registration and monitoring of certain types of deferred income plans. While the division's primary mandate remains unchanged, major changes to the legislation in 1992 as a result of Pension Reform increased the scope of this function, both in volume and complexity. In order to handle the diversity, complexity and increased volume of our workload, we have organized our RPD staff into specialized groups and sections.

To fulfil our mandate, we, in RPD examine and regulate the following types of plans:

• Registered Pension Plans (RPPs);
• Retirement Savings Plans (RSPs);
• Retirement Income Funds (RIFs);
• Educational Savings Plans (ESPs);
• Deferred Profit Sharing Plans (DPSPs);
• Supplementary Unemployment Benefit Plans (SUBPs);

We also examine and regulate investments within plans, by approving Registered Investments (RIs).

In performing these activities RPD provides the following services:

• disseminate information to the public and other government departments through:
  • our telephone enquiry service;
  • the documents that we publish; and
  • written replies on registration activities, the principles of pension adjustment calculations, and various technical issues;
• process applications for registration, and accept or deny amendments to plans; and
• approve the eligibility and the deductibility of contributions to registered plans after liaising with the Office of the Superintendent of Financial Institutions (OSFI).

RPD commitments in carrying out these services are to:

• provide clients with responsive and accessible service;
• answer clients' enquiries in simple, clear terms;
• interpret income tax law consistently, fairly, and according to its intent;
• monitor the plans we administer for compliance with the Income Tax Act and Regulations;
• strive for efficiency and continuous improvement; and
• foster good relations with our clients.

Registered Plans Division clientele

The primary client group for Registered Plans Division's services is the retirement savings industry which comprises plan administrators, benefit consultants, actuaries, financial institutions and employers who sponsor or participate in pension or other tax-assisted savings plans for their employees.

Other clients for these services include our tax services offices, and Headquarters functions such as Rulings, Technical Publications and Legal Services. We also serve provincial governments, federal government departments including the Department of Finance, and federal government pension regulators such as OSFI.

We participate twice a year at the Canadian Association of Pension Supervisory Authorities conferences. We also meet with clients in response to requests to discuss particular issues. We undertake other initiatives to improve efficiency and service to regulators and clients when cost-benefit studies indicate their worthiness.

Registered Plans Division services

We provide service for registered plans in three major areas.

• Information and advice

We provide oral and written responses to enquiries on matters relating to current and proposed legislation.

We also publish documents, such as guides and circulars, that deal with particular topics. These are available at tax services offices. As a further service to clients, we publish Registered Plans Division - Newsletter in response to a special need or to a request for clarification of a particular issue. We mail the newsletters directly to the pension industry; they are not available at tax services offices. You can obtain copies of the newsletters by contacting our Registered Plans Division at the address at the end of this publication. We have included a list of our publications with this newsletter.

• Processing applications for registration, and accepting or denying amendments to plans

We process applications for new RPPs, RSPs, RIFs, DPSPs, SUBPs, ESPs, and RIs. This includes processing requests for all amendments to existing plans, including amendments to terminate plans.

• Approval of eligible contributions

We process requests for approval of the eligibility and the deductibility of contributions to defined benefit pension plans. We refer these requests to OSFI for actuarial advice.

Registered Plans Division standards

An explanation of our services and the standards we have established is outlined below. For ease of reference we have also listed the standards in the table that follows on page six.

• Telephone enquiries

The enquiry lines are available on Monday to Friday from 8 a.m. to 5 p.m., Eastern time. Our client survey indicated that callers usually get through on the first or second attempt. It also showed that callers feel they receive a high level of courtesy and help, and a good response to their needs. Each year RPD receives about 30,000 calls from the pension industry. We also receive numerous calls from departmental and interdepartmental clients. Since the calls vary from basic to very complex, we have established the following goals for answering calls:

• Basic - answered during the first call;
• Simple - requiring a call-back, answered within one working day;
• Complex - caller advised that a call-back will take two working days;
• Very complex - the same as for complex, or we may advise the caller to submit the enquiry in writing, since it goes beyond the scope of telephone advice.

Our Registered Plans Division telephone numbers:
General enquiries, English (613) 954-0419
General enquiries, French (613) 954-0930
Pension adjustment (PA) enquiries, English (613) 954-5102
Pension adjustment (PA) enquiries, French (613) 954-5104
(local calls only)

Toll-free lines, English, (PA only) 1-800-267-3100
Toll-free lines, French, (PA only) 1-800-267-5565
Fax (613) 952-0199

Note: If you fax us it will reduce time spent in mail systems, but it will not give a submission priority over those in the normal work flow of regular mail.

Written enquiries

We deal with all written enquiries that relate to any of our processing operations on a first-in-first-out basis. In addition to these written enquiries, we receive a large volume of correspondence on other issues that may be general or case-file specific. The current service delivery standard for all such written enquiries is 60 days. Enquiries should be sent to the Registered Plans Division, Revenue Canada, 700 Industrial Avenue, Ottawa, ON K1A 0L8.

Pension plan registration

The registration process occurs in two distinct stages.

Deemed registration

A plan that is received for registration is given an initial review to ensure that the appropriate documentation and forms have been filed. If the application is complete we issue a letter to the client giving a plan number, as well as instructions on filing requirements and certain restrictions that apply to the plan until actual registration has been granted. This process allows plans to operate while they await a full review for final registration. Our current standard for issuing a deemed registration is 30 days. The peak period for registration requests is the calendar year-end. The volume of requests we receive in that period increases the standard to 60 days for a few months following the year-end.

Registration

The final registration process entails a detailed review of each application for registration to ensure that the plan text complies with prescribed conditions and requirements in the Income Tax Act. The current standard to conduct a first review of a request to register a new plan is 180 days. Plans that meet the requirements of the legislation are registered at that time.

RPP termination

We have recently published two newsletters outlining policies that are designed to streamline the termination process. Please follow the recommendations we make in newsletters 94-3 - Using Assumptions to Compute the Present Value of Benefits, and 94-4 - Wind-Up Valuation Report. The current standard to conduct a review of a request to terminate a plan is 180 days.

RPP amendment

We have not yet developed a standard for requests to approve amendments to RPPs because of the volume and complexity of amendments received as a result of pension reform. Our goal is to improve the turnaround time and develop standards to be published at a later date.

Eligible Contributions

We review for approval, requests for recommended contributions to defined benefit plans to determine their deductibility under section 147.2 of the Income Tax Act. The Minister approves recommended contributions on the advice of OSFI. As the time to complete this type of request can vary greatly, we are unable to provide standards for this activity at this time.

RSPs

We receive requests for approval of two main types of specimen plans: individual and group. Since these cannot be marketed until the Minister approves them, this is a priority. The current standard to complete new specimen RSP requests, or to amend or terminate existing specimen RSPs is 60 days.

RIFs

We handle Retirement Income Funds similarly to RSPs. The service delivery standard for approval, amendment, and termination of these specimen plans is 60 days.

Registered Plans Division Standards

• Basic call - immediate response
• Simple call - within one working day
• Complex call - within two working days
• Very complex call - may be advised to write in
• Written enquiry - 60 days
• Deemed registration - 30 to 60 days
• Registration - 180 days
• Termination - 180 days
• Amendment - not yet established
• Eligible contributions - not yet established
• RSP and RIF approval - 60 days

Note: The turnaround time for any of our services can be less if the submission complies with the law and if clients include clearly worded and complete documentation with it. The booklet T4099, Registering Your Pension Plan, explains what documents you should include to register or amend your RPP. You can get a copy at your tax services office.

Confidentiality

Under the confidentiality provisions of the Income Tax Act, generally we cannot give out client information to third parties without the client's written permission.

How to request Registered Plans Division's services

You can mail or courier written enquiries or submissions for registered plans to:

Registered Plans Division
Revenue Canada
700 Industrial Avenue
Ottawa ON K1A 0L8

We welcome your feedback on this publication. You can send your comments to the above address. You can also send complaints or compliments to that address, attention: Director of the Registered Plans Division.