How will crypto disclosure rules impact federally regulated pension plans?

By: Julius Melnitzer | April 25, 2023

In its 2023 budget, the federal government announced plans to require that federally regulated pension plan sponsors disclose their cryptocurrency asset exposure.

To that end, the Office of the Superintendent of Financial Institutions will be consulting with impacted organizations on the content of the forthcoming guidelines.

“Just how these guidelines will affect standards of governance or regulatory burdens will depend on the details,” says Jeffrey Sommers, a partner in pensions, benefits and executive compensation at Blake, Cassels & Graydon LLP. “What is clear is that the feds are looking at crypto as a unique asset class that requires continuous monitoring and special disclosure measures.”

The budget suggested the government will work with provinces and territories to discuss disclosure by Canada’s largest pension plan sponsors within their jurisdictions, but doesn’t specify whether all federally regulated plan sponsors, regardless of size, will be required to disclose. “The wording suggests that the government may be targeting only the largest plans, but how do you define ‘largest?’” asks Sommers. “In any event, the provinces would have to amend their legislation to mandate the disclosure.” MORE . . .

Julius Melnitzer is a Toronto-based legal affairs writer, ghostwriter, writing coach and media trainer. Readers can reach him at [email protected] or


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