Frequently Asked Questions - RPP Forms

1. Why is the CRA's Registered Plans Directorate changing the T510, Application to Register a Pension Plan, and the T920, Application to Amend a Registered Pension Plan?
2. Have there been any discussions with clients on these changes?
3. What are the changes to the T510, Application to Register a Pension Plan?
4. What are the changes to the T920, Application to Amend a Registered Pension Plan?
5. What happens if the T510, Application to Register a Pension Plan, and the T920, Application to Amend a Registered Pension Plan, are not fully completed?
6. How will these changes affect me? What are the benefits?
7. How will risk be determined and applied?
8. Does this mean that it will take longer to complete the forms?
9. Will these changes mean that there will be no review of your plan terms at registration?
10. Are there any new forms being introduced?

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1. Why is the CRA's Registered Plans Directorate changing the T510, Application to Register a Pension Plan, and the T920, Application to Amend a Registered Pension Plan?

When the pension reform legislation and associated regulations were introduced in 1989, the Registered Plans Directorate focused on helping plan sponsors, administrators, and consultants with the new registration requirements for plan wording. We believe our clients now have the information and skills to correctly draft plan terms to obtain registration under the legislation. As a result we are adjusting our focus and expanding our audit program to ensure that pension plans are being operated in accordance with their terms and the legislation.

Therefore, we have modified the forms to accommodate process changes announced in our November 1, 2005, letter (Re-engineering of Registered Pension Plan Processes ). The redesigned forms ask for more specific information to help us identify areas of risk and speed up our processes.

2. Have there been any discussions with clients on these changes?

On March 9, 2005, the Registered Plans Directorate held the inaugural meeting of the Pension Advisory Committee (PAC) in Ottawa. This committee was made up of pension consultants, actuaries, and plan administrators. There were a number of subcommittees within PAC that were mandated with making proposals for changes to communications, technical issues, and procedural policies. The forms have been reviewed by the communications subcommittee. The subcommittee had a number of suggestions that were incorporated in the final versions.

3. What are the changes to the T510, Application to Register a Pension Plan?

As well as collecting basic information about the sponsoring employer, funding media, plan administrator, etc., the form now incorporates a series of "Yes/No" questions that must be answered. We have also expanded the form to provide space for the submitter to provide details such as: the employer and employee contribution rates, a definition of earnings, and how additional voluntary contributions are determined if provided. Also, for those who are not familiar with pension plans, some terms in the form are linked to a webpage that contains a plain language glossary .

We have also added a section to identify the documents enclosed with the submission.

Since the T510 is a prescribed form, you must use the most recent version in the circumstances described (check our website for the most recent version).

You must use the new form starting October 1, 2007. After September 30, 2007, we will not accept applications that use a previous version of the form. Also, we will not accept an incomplete form. In both cases, we will return the form to the sender.

In Newsletter 04-2 , Registered Pension Plan Applications - Processing an Incomplete Application) published April 30, 2004, we detailed our procedure for dealing with incomplete applications for the registration of pension plans.

4. What are the changes to the T920, Application to Amend a Registered Pension Plan?

The T920 has been modified significantly more than the T510, Application to Register a Pension Plan. One change that came out of consultations with our clients was the removal of sections that dealt with name and address changes of the plan sponsor, administrator, consultant, or funding media. Changes that do not result in an amendment to the plan documents do not require a T920.

A new form, T2011, Change of Information Form, will be available for use for this purpose (see Question 11 below).

Section 2 of the T920 now consists of a series of "Yes/No" questions that relate to the amendment and asks for details of the change(s). By identifying and specifying the changes, it is expected that the processing time of the amendment(s) will be shortened. Also, for those who are not familiar with pension plans, some terms in the form are linked to a webpage that contains a plain language glossary .

Since the T920 is a prescribed form, you must use the most recent version in the circumstances described (check our website for the most recent version).

You must use the new form starting October 1, 2007. After September 30, 2007, we will not accept applications that use a previous version of the form. Also, we will not accept an incomplete form. In both cases, we will return the form to the sender.

We are expanding our procedures relating to incomplete applications (See Newsletter 04-2 , Registered Pension Plan Applications - Processing an Incomplete Application) to include plan amendments as well.

We have also added a section to identify the documents enclosed with the submission.

5. What happens if the T510, Application to Register a Pension Plan, and the T920, Application to Amend a Registered Pension Plan, are not fully completed?

In Newsletter 04-2 , Registered Pension Plan Applications - Processing an Incomplete Application) published April 30, 2004 we detailed our procedure for dealing with incomplete T510 applications for registration. Incomplete forms, or forms that lack full documentation will be returned to the submitter for completion.

This policy will be extended to the submission of T920 and associated documents.

What is an incomplete form or a form that lacks full documentation?

All questions on the forms must be answered. In the sections that request you to provide specific information, such as the benefit formula, we would require the complete formula on the T510 or the complete changed formula on the T920 (not just the part of the formula that changed). The information is to be put on the form or attached to the form on a separate sheet that references the appropriate question on the form. We will not accept a reference to the section of the plan text as providing a completed form.

We are not requesting information on all types of changes that could be made to a pension plan on the T920. For example, we do not ask if the amendment adds or changes an existing bridge benefit. If the change made to the plan is not identified on the form, you do not have to identify the change in Section 2. However, this does not change the requirement that a T920 is always required when a submission is made to amendment a pension plan.

The part entitled "Other" in Section 2 of the T920 form is for changes you would like to identify to us. For example, you may want us to know that this amendment changes variables of a pension plan based on a specimen. This type of identification would assist us and speed up the process.

6. How will these changes affect me? What are the benefits?

Depending on the risk level of a plan (see Question 8) sponsors can expect quicker service. For example:

• Shorter response time for registration requests: By providing the requested information, the Registered Plans Directorate will be able to determine a plan's risk level more easily. Lower risk plans (such as money purchase plans, defined benefit plans with more than 10 employees, and plans based on an approved specimen plan) will be processed faster than plans that are considered to be at higher risk (such as individual pension plans, designated plans, or plans with persons connected to the employer).
• Immediate acceptance of low risk amendments: By identifying the changes and providing the information, there will be fewer requests by the Registered Plans Directorate to clarify specific wording or interpretations of wording in the plan text. The onus will be on the sponsor and the administrator to ensure that what is provided on the form matches the plan terms, and that those terms are in accordance with the Income Tax Act and Regulations.

7. How will risk be determined and applied?

The Registered Plans Directorate has developed risk indicators for pension plans. These risk indicators are based on past experience and will help identify those plans that have a higher risk of contravening the legislation. For plans identified with a higher risk level, there will be an increased likelihood of being reviewed prior to registration, audited after registration, or reviewed prior to acceptance of an amendment.

The Registered Plans Directorate will continue to review and modify these indicators based on audit results, industry trends, and other factors.

8. Does this mean that it will take longer to complete the forms?

By providing more information on the forms, they may take longer to complete, but we expect that there will fewer subsequent requests for information.

9. Will these changes mean that there will be no review of your plan terms at registration?

Plan documents that are submitted for registration or plan amendment will be initially reviewed to ensure that the application is complete. Following this assessment, some plans will have specific sections of the plan terms reviewed to ensure that the wording is acceptable. Other plans will not have their terms reviewed at registration. However their plan terms may be reviewed later as part of an audit of the plan administration.

10. Are there any new forms being introduced?

In addition to the redesigned T510 , Application to Register a Pension Plan, and T920 , Application to Amend a Registered Pension Plan, we are introducing two new forms for use by our clients:

• The T2011 , Registered Pension Plan Change of Information Form, is designed to replace the name and address fields from the T920 (check our website).
• The T2014 , Registered Pension Plan Priority Identification Form, was created for clients to self identify high priority items (check our website).

The T2011 and T2014 are not prescribed forms. As a result, their use is not mandatory. Clients that submit documentation that includes change of address information or high-priority items must identify these items. Failure to do so may cause a significant delay in our response. The new forms are provided to help in this process.