Standard Life made public today its comments on the proposals that the Joint Forum of Financial Industry Regulators made last April regarding employer-sponsored pension plans and group RRSPs.

Although Standard Life supports the initiative to develop effective regulation of capital accumulation plans, the insurer says it believes that further improvements can be made especially in terms of clarity, transparency and practicality to the existing guidelines.

“We are concerned that the proposed guidelines are not conceived to make things simpler,” said Claude Garcia, president of the Canadian operations of Standard Life, in a news release..

Garcia lamented the lack of harmonization across Canadian jurisdictions, and the lack of coordination within the insurance, pension and securities sectors. He said the consequences will be over-regulation, confusion and even conflicting regulations for everyone involved.

“In fact, we see two major problems. The first is that the guidelines’ goals need to be clearer vis a vis investment issues. As they stand, there are three possible interpretations, which lead to different outcomes. The second problem,” continued Garcia, “is with the content of the statement provided by sponsors.”

To outline the first problem, the company submitted a brief that explained each interpretation, followed by Standard Life’s recommendation to the Joint Forum and the different options available to fix this problem. “We are asking the Joint Forum to endorse the position that the investment provisions of all three regulatory regimes are sufficiently similar that compliance with any one of them is adequate,” stated Garcia.

The second issue at hand is the content of member statements. Standard Life suggests that easy access to information for plan members is crucial. “Although we strongly believe in making our statements clear and easy to follow, we are not ready to make these more costly without any real benefits to the member. As the draft text stands, providers would have to enumerate each transaction made within the year. This means that a member who is paid 26 times a year, invests in five different funds and has three sources of contributions would end up with a statement with close to 400 lines. Obviously this is not a practical solution. Rather, we suggest making this level of intricate detail available to any member upon request,” said Garcia.