Public Affairs Council Update
By Bernard Morency, FCIA
In September 2018, the Public Statements Committee became the Public Affairs Council (PAC). Our group’s mandate (log in required) was reinforced as the Board asked us to oversee the production of level-two statements and to be more proactive in identifying issues on which the CIA should comment. Furthermore, the upgrade to council status reinforces the importance of public statements to the CIA’s strategic priorities and successes.
What is the Purpose of the PAC?
The council was created to help fulfil the 2017–2019 CIA Strategic Plan’s goal of influencing public policy: “Meaningful and timely contributions to public dialogue allow the CIA to serve the public interest and the actuarial profession, and to be recognized as a key player in matters of public policy.”
In 2018, the CIA published 27 submissions, compared to 15 in 2017. Clearly, we have seen a huge increase in the number of requests for our opinion, and it is not slowing down. We commented on a wide range of topics for a diverse group of stakeholders including the following:
- Submissions on funding rules for registered pension plans in Nova Scotia, Québec, Ontario, and Manitoba;
- Submissions to the International Accounting Standards Board (IASB) on the extension of the IRFS 17 implementation date, to the International Association of Insurance Supervisors (IAIS) on ICP 20, and to the International Actuarial Association on IAA Restructuring;
- Submissions to the Office of the Superintendent of Financial Institutions (OSFI) on its reinsurance framework, to Retraite Québec on disbursement rules, and to the federal government on enhancing retirement security for Canadians; and
- Letter to a number of provincial governments on the regulations concerning premium rates for automobile insurance.
Although we do not actively publicize all of our submissions, we have nonetheless received valuable media coverage, such as this recent article in Benefits Canada on our submission to the federal government on enhancing retirement security for Canadians. It is clear that the voice of Canadian actuaries is in growing demand, and our submissions continue to be an important way to share it.
Where We Will Go in 2019
The council is looking forward to good success in 2019 in a number of areas:
Level-one public statements, which we call submissions, are usually in response to government or regulators regarding proposed legislation or guidelines or a request for clarification of a CIA standard of practice or guidance note. Sometimes we are proactive and prepare a submission and solicit a discussion with government authorities on a matter of interest to the public where we feel actuaries have a contribution to make. One such instance is a letter sent the Minister of Finance, Bill Morneau, on enhancing flexibility for the decumulation of pension savings at retirement. This letter was co-signed by a number of groups/associations including the CIA.
The increasing quantity, diverse content, and range of complexity of these documents has shown that not all level-one statements require the same process and attention. Therefore, the PAC, with Board approval, has recently updated the steps involved. When necessary, a submission can be flagged as “complex”, triggering a closer technical review by an additional group of subject-matter experts (e.g., the International Affairs Council for topics of global relevance, or the Pension Practice Committee for topics in their area of expertise, or any other number of CIA bodies). Furthermore, the PAC is committing to more robust follow-up and tracking to better understand the impact and reach of these statements with their target audiences.
Level-two statements are those that require member input and Board ratification prior to their release. Such statements could be a new public position in a non-traditional practice area, a position in a traditional practice area that the CIA has not articulated previously, or any position on which there could be a significant number of differing views within the membership.
We are currently working on three level-two statements: retirement age, climate change, and risk classification. The retirement age statement is the furthest along, having completed a membership comment period in late 2018. We received valuable input, with 37 sets of written comments from groups of actuaries or companies. The Single Topic Task Force on Retirement Age recently finished reviewing these comments and updating the document. It is now being finalized with editorial and design work, and the PAC is reviewing the final version ahead of Board ratification for a spring release.
The climate change statement is nearing a version ready for membership review, while the risk classification statement is under development. The PAC’s goal for 2019 is to have at least two level-two statements released, and to start working on two new level-two statements.
The Council and its Members
One of the PAC’s successes is that when we receive a request, we have a clear process for approving that request through an authorizing committee.
I strongly believe that it is very important that all members of the PAC have an opportunity to review and comment on all submissions. There is great value in the expertise outsiders bring when they look at these statements. Statement authors provide a detailed view inside of a topic usually responding to a stakeholder who has requested our comments. PAC members see all submissions. In addition to keeping an eye on the clarity of our position and consistency with prior ones, we think about how the submission will resonate with the public and with our members.
It is this duality that enables the CIA to respond to requests and influence public policy with a well-reasoned authority that decision makers appreciate.
Bernard Morency, FCIA, is Chair of the Public Affairs Council.