How CIA Public Positions are Developed


By Elliot Hughes

On Tuesday, November 10, the CIA released its latest public position, this one on the Canadian retirement system and what steps are required to ensure that the needs of Canada’s future retirees are met. The paper relied on the knowledge and insights of some of Canada’s leading pension actuaries, with the solutions put forward offering a well-lit path. The paper was well-received by governments, interest groups, and the media alike.

But how did the public position come together? Who decided on the topic? Who wrote and reviewed it? And where was it sent? The purpose of this piece is to answer some of those questions while providing greater insight and transparency into how CIA public positions are made.

At its core, a public position, and the policy that sits behind it, is meant to establish and document the views of the Institute. A public position could emerge in response to a call for input (e.g., a government consultation), as a reaction to an issue or event (e.g., long-form census), or as a proactive statement (e.g., national pension champion). But the form the response takes isn’t what matters most. What matters is the content and how it is decided upon. Only after the content has been agreed upon, and with the help of the CIA’s internal and external experts, is a decision made about which communication tool is most appropriate to reach its intended audience.

Before going further, it is worth explaining who the policy on the approval of public positions is for and what the approval process does not apply to. First, the policy is for use by the Board, the CIA Public Positions Committee (PPC), and other Institute bodies (i.e., councils, committees, designated individuals) tasked with drafting positions on behalf of the Institute. The policy does not, however, apply to material covered under the Policy on the Approval of International Submissions, or the Policy on Due Process for the Approval of Guidance Material other than Standards of Practice and Research Documents. Additionally, it does not apply to committee or task force reports or research reports. With that covered, let’s move on to how a position is developed, approved, and distributed.

The need or interest in developing a public position tends to materialise through one of three ways: a government consultation announcement, a news story or event, or a request from a CIA member. In the case of the recent pension position, it emerged out of a federal government consultation on Canada Pension Plan (CPP) expansion and the desire to position the CIA in light of political commitments made during the federal election. From these requests, the President and Executive Director determine whether it is appropriate for the CIA to develop a public position. If both individuals approve, they turn their attention to appointing a drafting entity made up of CIA members. These members will most likely have specific expertise in the topic or practice area, though they may also have an understanding of the specific regulatory environment or simply be interested in the topic. In some cases, we may even choose an existing CIA committee to serve as the drafting entity if their area of expertise aligns with the subject matter. Needless to say, the drafting entity is always made up of highly qualified, dedicated, and well-intentioned members. With the pensions position, that drafting entity was made up of 10 experienced industry experts, who have been involved for years in the design, administration, and funding of private and public pension plans.

To ensure Board oversight, the President, if he or she wishes, may serve on the drafting entity. If the President chooses not to serve on the drafting entity, they must be part of the authorizing committee which consists of at least three CIA members (under certain circumstances, this number could be higher). Again, like the drafting entity, the authorizing committee tends to be made up of members with a related set of knowledge and background. In fact, the approval policy calls for at least two such members, and explicitly calls for one member to be from outside the practice area. When a public position is not related to a particular practice area, that requirement can be waived.

With help from the CIA Head Office, the public position is shared with all members of the PPC, who provide their comments to the authorizing committee. The authorizing committee is then asked to render one of three decisions:

i. Approve the public position as written;

ii. Approve the public position subject to minor editing; or

iii. Return the public position to the drafting entity for further editing, along with the reasons for the return.

It’s worth mentioning that the authorizing committee may not modify the public position, alter the message, or substantially change the content. This process ensures that the group tasked with drafting the position—those with the experience and knowledge in that particular practice area—are the ones developing the position. However, what makes this policy so robust is that it also ensures the President is involved in every public position. The authorizing committee for the pension position was made up of five members (an increase from the usual three).

Once changes have been made and the position finalized, it is sent to the CIA Head Office and prepared for distribution. To be clear, it is the drafters and the drafters alone who decide on the content of the position, with the role of CIA Head Office restricted to formatting, editing, and translation. Published and distributed in both official languages pursuant to detailed procedures outlined in the approval policy’s appendix, the goal is to distribute the position to the appropriate audience, be it the public, a government agency, or the press. Importantly, it also means notifying CIA members, usually through the weekly announcements and in both official languages, to ensure members are kept up to date on the Institute’s activities. Positions are then discussed in various formats such as webcasts, the General List, or annual meetings. Feedback is not only expected, but welcomed.

Finally, in some instances public positions require the appointment of spokespeople who can communicate the position to the press or an external body on behalf of the Institute. These individuals are designated by the President and Executive Director and are empowered to speak on behalf of the Institute and represent, to the best of their ability, the spirit and intent of all public positions approved by the Institute. Yearly updates are conducted on both the list of authorized spokespeople for each public position, as well as the public positions themselves, to ensure we remain current. In the case of the pension position, the primary spokespeople were Rob Stapleford, President of the CIA and Michel St-Germain, Chair of the Pension Advisory Committee (PAC). Providing additional support were various other PAC members, who are comfortable in both official languages.

We hope you found this article informative and the process robust. For more information, please visit the Policy on the Approval of Public Positions on the CIA website. Alternatively, you can contact Chris Fievoli, the CIA’s resident actuary and staff member charged with supporting the PPC’s work. Finally, we encourage you to visit the CIA’s Outreach page where you can review past positions, submissions, and resources.

Elliot Hughes is public affairs manager at the CIA Head Office.

Canadian Institute of Actuaries/Institut canadien des actuaires