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The CIA and public positions

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By Michel St-Germain, FCIA

I am sure you have noticed that there has been a significant increase in the number of submissions of public positions prepared by the CIA. Those include:
  • Submissions to OSFI and AMF on the supervision of insurance companies;
  • Responses to requests from regulators on proposed changes to pension laws;
  • A position on the role of government-facilitated retirement income plans including an increase in the Canada Pension Plan;
  • The first Retirement Risk Survey, illustrating the concerns of Canadians on retirement planning, the adequacy of retirement income and the needs for health care after retirement;
  • Proposed changes to accounting requirements under IAS;
  • A position on the elimination of the mandatory requirement of the long-form census; and
  • A position on self-funded long-term disability programs.
This follows a strategic choice by the CIA to be more active and participate in public debate on issues relevant to our profession. Indeed, taking public positions will:
  • Improve actuaries’ image and let more officials know of our special expertise; and
  • Correspond to our objective of serving the public interest before our own interests.
But, more importantly, we are taking public positions because we have something to contribute to some important debates. Actually, many of us, individually or through our employers, have been active in public debates and in submitting comments to public officials.

A few years ago, the Institute adopted a process for the development of public positions. It starts with the identification of an opportunity to prepare a submission, and this may come from an outside request or a suggestion from a CIA committee, or from an individual member. After consultation, the President and the Executive Director must agree that a submission is appropriate, appoint a Governing Entity (usually the Board, the Member Services Council or the Practice Council). Then, the Chair of the Governing Entity appoints an Authorizing Committee and a Drafting Entity. The latter will:
  • Research the issue;
  • Develop a CIA position;
  • Write the submission; and
  • Seek approval from the Authorizing Committee after the Governing Entity has had an opportunity to review and comment on the draft.
Being a member of the Drafting Entity is an excellent opportunity to contribute to the Institute. If you hear of such opportunity and would like to contribute, do not hesitate to let that be known.

There are some challenges in preparing these submissions:
  • Some topics are controversial. A firm position of the CIA may be criticized by the public; at times, we avoid taking a position and present alternatives with analysis of pros and cons.
  • Not all actuaries will agree with a position of the CIA, or with the way it is presented and the arguments used.
  • At times, our position may not fit within the field of pure actuarial expertise; some may argue that we should stay within our area of expertise.
But I do believe that our efforts are worthwhile and we can contribute something back to society. The submissions made on pension reform are a testament to this. We have helped public officials improve their understanding of these issues. As the great pension debate is not over, I am expecting that the CIA will continue to participate in the discussions on whether Canadians should save more for retirement, what is the best way to save, when should we save for retirement, what should be the respective role of government, employers and individuals, and how can defined benefit plans survive?

There will be other public hot topics. The aging of the population is increasingly perceived as one of the major challenges of our society, and in particular its effect on healthcare costs. Surely actuaries can participate in this debate.

Michel St-Germain, FCIA, is Chair of the Member Services Council.

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