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This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.

Approving Authority: Board of Governors

Original Approval Date: November 19, 2009

Date of Most Recent Review/Revision: N/A

Office of Accountability: VP Finance and Administration

Administrative Responsibility: Human Resource

Purpose

1.00 The purpose of this policy is to define the categories of usual and reasonable expenses related to the administration of the Wilfrid Laurier University Pension Plan (the “Plan”) eligible for reimbursement from the Plan subject to rules outlined in the Pension Benefits Act, the Plan Text and trust agreements, and as permitted by common law.

Jurisdiction/Scope

2.00 This policy applies to expenses related to the registered Plan only. Expenses arising from non-registered pension or benefits plans are not eligible under the terms of this policy.

Policy

3.00 The Wilfrid Laurier Pension Plan is registered with the Financial Services Commission of Ontario (FSCO). Payment of expenses from the Plan are subject to rules outlined in the Ontario Pension Benefits Act, the Plan text and trust agreements, and as permitted by common law. As part of WLU’s overall pension governance, and in their role as Plan Administrator, it is important to formalize a policy outlining the guiding principles for the payment of expenses related to the administration of the registered Plan. WLU’s philosophy around the treatment of Plan expenses is that all legitimate expenses reasonably necessary for the administration, integrity and existence of the Plan will be charged to the Plan.

Eligible Expense Categories

WLU will charge to the Plan all legitimate expenses reasonably necessary for the administration, integrity and existence of the Plan. Based on Financial Services Commission of Ontario (FSCO) policies, case law, and common practice the following categories of expenses will be considered usual and reasonable and therefore will be charged to the Fund unless the University decides to pay such expenses directly. The Office of the Vice-President Finance and Administration will be accountable for reviewing and approving expenses to be paid from the Fund in accordance with applicable legislation and the terms of this policy.

Actuarial expenses including:

• Actuarial retainer and other actuarial services related to the administration of the Plan (benefit calculations, processing of pension split at marriage breakdown, etc)
• Asset/Liability studies
• Funding valuation reports
• Inter-valuation period monitoring and forecasting
• Pension Plan accounting valuation report for WLU financials (required under accounting standards)
• Pension Plan accounting audits for employer financials

Plan administration expenses including:

• Producing plan amendments including government filing and notice to members
• Employee communication and education (plan booklets, information sessions, session related to retirement and the WLU Pension Plan, member consultations etc)
• Annual Member Statements
• Fees to Third Party Administrator for day to day pension administration (enrolments, termination and retirement statements, pension adjustments, death statements etc)
• Annual Plan governance/compliance reviews
• Audits from the regulators (e.g. cost of compiling requested data and documents)
• Implementation of Plan Design changes (update documents, regulatory filing, member communication)

Trustee/custodial expenses including:

• Trustee/custody charges
• Other trustee/custodial services including reporting, transaction charges, pension benefit payment services etc.

Investment expenses including:

• Investment Manager fees
• Investment Manager performance assessments
• Investment Consultants (if applicable)
• Fund Manager Searches

Other expenses including:

• Audited Financial Statements of the Plan Fund (fees from audit firm)
• Salaries and related expenses of University staff whose job relates directly to the administration, integrity and existence of the Plan (based on the regular and ongoing percentage of time devoted to pension matters)

The following expense categories based on Financial Services Commission of Ontario (FSCO) policies, case law, and common practice are not payable from the Fund.

Expenses not payable from the fund:

• Accounting for non-pension post-employment benefits
• Costs associated with the administration of the non-registered Supplemental Pension Arrangement (SPA)
• Fees associated with analysis, preparation for union negotiations
• Fees associated with the Pension Benefits Guarantee Fund (if the employer is making special payments to the Fund)
• Analysis of Plan design changes that are not implemented
• Retirement/life planning consultations/sessions (unrelated to WLU Pension Plan)

GST Rebates

Recovery of GST on eligible expenses charged to the Plan will be administered in accordance with Canadian tax rules. Until such time that legislation permits pension plan trusts to receive GST refunds directly, the University will pay the eligible expenses including the GST, affecting the immediate recovery of the refundable portion of the GST. The University will then charge the Plan for the net expense after GST recovery and the Plan will then reimburse the University for the net eligible expense after GST recovery

Relevant Legislation/Compliance

The Pension Benefits Act, the WLU Pension Plan text, and the WLU Pension Plan trust agreements (both historical and current) have always given WLU the authority to direct that all of the expenses related to the administration of the WLU Plan and the WLU Plan fund shall be paid from the Fund.

Roles and Accountabilities

Office of the Vice-President Finance and Administration

To review and approve expenses to be paid from the Fund in accordance with applicable legislation and the terms of this policy. To update this policy, as required, to ensure compliance with applicable legislation.

Service Providers (Including Actuary, Third Party Administrator, Auditor, etc.)

In preparing invoices, will clearly describe on the invoice the nature of the expense and will recommend payment from the Fund, or outside of the Fund, based on applicable legislation and the terms of this policy.

Pension Committee of the Board

To establish, adopt and periodically review and amend as required an expenses policy for the Pension Plan. Further, to regularly monitor compliance by all participants with this policy and to determine an appropriate action for non-compliance.