Alberta Pension Plan - Analysis of Costs, Benefits, Risks and Considerations

Alberta Pension Plan –
Analysis of Costs, Benefits,

Risks and Considerations
Report from LifeWorks
August 2023
Table of Contents
Executive summary .................................................................................................................... 1
Background ................................................................................................................................. 5
History and features of CPP ....................................................................................................... 6
Key features of an Alberta Pension Plan................................................................................... 8
Process for withdrawing from the CPP ................................................................................... 20
Transition considerations ........................................................................................................ 22
Delivering an APP ..................................................................................................................... 26
Opportunities for additional analysis ...................................................................................... 35
Appendices ............................................................................................................................... 36
Glossary .................................................................................................................................... 37
Appendix A: Additional considerations for an APP ............................................................... 38
Appendix B: Additional discussion of Asset Transfer from CPP to an APP ........................ 47
Appendix C: Detailed APP financial results and actuarial model .......................................... 53
Appendix D: Additional legal and governance considerations ............................................. 82
Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | i

Executive summary
Alberta Treasury Board and Finance (ATBF) has engaged LifeWorks to prepare a detailed analysis
of the costs, benefits and structure of a potential Alberta Pension Plan (APP). This analysis includes
actuarial, economic, legal, and technical information regarding the establishment and ongoing
operation of an APP. This analysis will give ATBF a clearer picture on what a future provincial pension
plan may look like and help answer key questions that Albertans are asking about the costs and
benefits of such a move.
This report does not contain any recommendations or endorsements relating to the creation and
operation of an APP; nor does it contain any opinion or recommendation in relation to the current or
future operation of the Canada Pension Plan (CPP).
It should be noted that analysis like this is complex when dealing with a social security program like the
CPP that has been in operation for over 55 years and covers nearly all working and retired Canadians
outside of Québec. We have reviewed considerable amounts of data and legislation, built and calibrated
a complex valuation model and performed significant analysis in order to summarize the information
and prepare this report. We have prepared our cost estimates based on publicly available information
and aggregate data, and methodology consistent with that used to determine contribution requirements
under the CPP. While we have confidence in the reasonableness of the results provided, a final APP
contribution rate based on actual data including asset amounts and individual CPP membership data
as well as a different methodology/philosophy for funding benefits could produce different outcomes.
The key questions considered in this report are:

• Could Alberta withdraw from the CPP? If so, what is the process and timeline?
• What would the level of pension benefits and associated contribution rate be for an APP?
• What are the considerations for a successful transition to an APP?
• How would the establishment of an APP affect other government programs?
• What are the set up and ongoing costs for an APP and who could be the service providers for an
APP?
This section will provide an overview of the more detailed results provided in the following sections.
Could Alberta withdraw from the CPP? If so, what is the process and timeline?
According to the Canada Pension Plan Act (the CPP Act), Alberta can withdraw from the CPP and
set up its own APP. Under the CPP Act, a province can withdraw from the CPP if it meets the
requirements outlined below. The other provinces are not legally entitled to a formal role in the
withdrawal process or a veto over the withdrawal. In order to meet the prescribed withdrawal
requirements, the replacing provincial plan must:
1. Provide notice in writing of its intention to withdraw from CPP in accordance with Section 3(1) of
the CPP Act;
2. Accept contributions beginning in the third year following the year in which the province gives
written notice of its intention to withdraw from the CPP;
3. Provide comparable benefits to the CPP; and
4. Assume all obligations and liabilities accrued and accruing in the CPP for members residing in the
province up to the beginning of the third year following notice.
Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 1

Based on these conditions above, and for the purposes of this report solely, we have made our
calculations based on notification being provided on January 1, 2024, with an APP being effective on
January 1, 2027, and that the level of APP benefits would be the same as the CPP. Note, we have
not been provided a timeline or indication that Alberta is pursuing this option; the notification date
chosen was merely for illustration purposes.
An APP would also be entitled to a share of CPP assets. The calculation of this amount is set out in
the CPP Act and is equal to Albertans’ contributions less benefit payments and expenses accumulated
with net investment earnings. Using publicly available information, we estimate this asset amount to
be $334 billion at January 1, 2027 for the Base CPP using our reasonable interpretation of the CPP
Act. This represents approximately 53% of the total estimated Base CPP assets on this date, which
is significantly higher than Alberta’s representative population in the CPP, which is about 15%. Due
to Alberta’s younger population, higher pensionable earnings, and higher employment rates,
contributions by Albertans to the CPP have historically exceeded the benefits paid to Albertans.
The corresponding estimated amount of asset transfer with respect to the Additional CPP is estimated
to be $16 billion as at January, 1, 2027, which is about 17% of the Additional CPP assets. The
Additional CPP has only been in place since 2019, and because of this, the historical difference
between contribution and benefits observed in the Base CPP for Albertans does not have the same
impact on the asset transfer amount from the Additional CPP.
What would the level of pension benefits and associated contribution rate be for an APP?
As noted in the prior section, for the purposes of our analysis, we have assumed that an APP’s
benefits would be the same as the CPP. Alberta could amend or change an APP once it has been
established. If and how Alberta decides to unilaterally amend or change an APP would need to be
outlined in its enabling legislation, and considered in the governance of an APP.
We have used substantially the same assumptions as used in the CPP 31 Report to project the Alberta
population for the purposes of this analysis. As a result, over the long term, the Alberta population is
projected to eventually become comparable to the general CPP population with the benefit of Alberta’s
current younger demographic being dampened.
Given the size of the expected asset transfer from the CPP and Alberta’s current younger
demographic, a Base APP would also be able to deliver benefits over the long term at a lower cost
than the Base CPP. However, the cost of an Additional APP would be similar to the Additional CPP
since current Alberta demographic advantages are assumed to disappear over the long term. The
following table compares the estimated Base and Additional APP contribution rates, the minimum
required sustainable CPP contribution rates from the CPP 31 Report, and the legislated Base and
Additional CPP contribution rates. Note that the Additional CPP benefits are divided into two levels
and are being phased in between 2019 and 2025.
Table 1 – Comparison of contribution rates under an APP and the CPP

Estimated Minimum Minimum Contribution Rates CPP –
Contribution Rates for for the CPP – CPP 31 Report Legislated
an APP Rates
Base Benefit 5.91% 9.54% 1 9.90%
First Additional Benefit 1.98% 1.97% 2.00%
Second Additional 7.92% 7.88% 8.00%
Benefit
1 The CPP 31 Report discloses CPP Minimum Contribution Rate of 9.56% for 2025-2033, 9.54% for 2034+.

These contribution rates for an APP translate into an estimated aggregate contribution savings of
approximately $5 billion in the first year (2027) of an APP’s operation, due to the lower contribution
requirements for the Base APP. On an individual basis employees and employers would each have
approximate full year savings of up to $1,425 per employee. This individual savings estimate applies
for individuals whose earnings are at or above the estimated 2027 Year’s Maximum Pensionable
Earnings (YMPE) 2 level; for those with lower incomes, the dollar savings will be proportionately lower.
It is important to note however that if an APP is established, the Government of Alberta may set a
legislated rate for an APP that is different from that of CPP, and also different from the minimum
contribution requirement. For example, it may set a rate higher than the minimum contribution
requirement to provide contribution stability. If the legislated rate is set higher than the minimum
contribution requirement, then the savings estimated above will be less.
With this type of actuarial calculation, we have to make assumptions about economic and
demographic conditions decades into the future. Different assumptions or different experience could
impact these contribution rates. In addition, the Base APP contribution rates are sensitive to the asset
transfer amount from the CPP. The body of the report and appendices contain additional analysis and
sensitivities that will assist in understanding the factors impacting these contribution rates. Further,
the contribution rates in our report display the same level of significance as those presented in the
Actuarial Report on the Canada Pension Plan as at 31 December 2021 (the CPP 31 Report) for
comparability but this inherently overstates the actual degree of precision of the results presented.
What are the considerations for a successful transition to an APP?

The project of transitioning away from the CPP to an APP would be an extremely large and complex
endeavour. The three-year timeline associated with notifying the Canadian Minister of Finance of the
withdrawal to set up an APP will be a constraining factor and will require strong vision, organization, and
execution. Once an APP becomes active, it needs to ensure that it has a structure in place to collect
contributions, administer, pay and adjudicate benefits, and invest the assets.
In the report, we consider in more detail the pieces needed for a successful transition to an APP, but
they can be summarized into the following categories:
1. Develop the framework for implementing and delivering an APP (plan design, investment
management structure, governance, service providers);
2. Draft legislation, and develop CPP/Québec Pension Plan (QPP) agreements for coordinating
benefits, and international social security agreements;
3. Setup service providers and implementation;
4. Communicate with Albertans and employers.
How would the establishment of an APP affect other government programs?

There are a number of pieces of legislation in Alberta, including long-term disability, workers’
compensation, and income support that include provisions for means testing/benefit adjustments that
make reference to the CPP. This set of legislation would need to be adjusted for an APP as well.
While beyond the scope of this analysis, the enactment of an APP would also cause other provinces
as well as the federal government to review their legislation to ensure coordination.
2 The estimated YMPE for 2027 is $75,400 provided in Table 4 of the CPP 31 Report.

What are the setup and ongoing costs for an APP and who could be the service providers of
an APP?
As noted above, setting up and delivering an APP is a significant task. An APP would be unique in that
it will need to deliver at a significant scale right from the beginning, instead of organically growing
operational capacity over time. The setup costs, in both time and dollars, for an APP will depend on the
service provider model selected.
This report considers the different service provider options for contribution processing, benefit
payment, dispute adjudication, investment management, actuarial services and auditors. The options
generally considered are existing CPP providers, existing Alberta public sector providers, new APP
providers, and private sector options.
We estimate that the setup costs for non-investment related activities will be between $100 million
and $1,000 million. At the low end estimate, we have assumed that an APP would leverage existing
CPP providers, whereas the high end assumes that an APP would set up completely new service
providers. We estimate that initial ongoing annual non-investment related costs would be between
$100 and $150 million.
In addition, the implementation costs for setting up the investment management structure could be
between $75 and $1,200 million. Similar to the above, the lower end assumes that an APP leverages
an investment manager with the size and expertise to manage the plan, whereas the high end
assumes a new APP investment manager with the size and expertise to replicate the Canada Pension
Plan Investment Board (CPPIB) is implemented. Ongoing investment management fees will depend
on the asset structure of an APP and we have assumed they will be deducted from the gross
investment returns.
If Alberta decides to leverage existing Alberta structures or create new ones to deliver an APP, then
an APP could create up to 1,500 to 2,000 long term jobs in addition to the (temporary) jobs needed
for implementation. These new jobs would not necessarily be based in Alberta. However, we would
anticipate many of the jobs would be Alberta-based, and the number of new jobs and their location
will be a function of the approach Alberta undertakes in implementing an APP.
Respectfully submitted on behalf of LifeWorks,
[Redacted to protect privacy - Original signed]

Background
Background and purpose
The report to the Government of Alberta (the Province) by the Fair Deal Panel covered many
recommendations, including recommendation 13, which states that the Province should take unilateral
steps to:
(a) Develop a comprehensive plan to create an Alberta Pension Plan (APP) and withdraw from the
Canada Pension Plan (CPP), and
(b) Subsequently, provide Albertans the opportunity, via a referendum, to vote for or against
withdrawing from the CPP and creating an APP.
Building upon this recommendation, the Province engaged LifeWorks to prepare this report, which
contains analysis related to the costs, benefits, and operating structure of an APP. The analysis
contained in this report has been prepared by LifeWorks’s team of actuaries, lawyers, investment and
administration professionals, and supplemented by additional legal analysis by Blake, Cassels &
Graydon LLP. This report has been based upon the assumptions, data and results from the CPP 31
Report.
The objective of this report is to provide a clearer picture on what an APP may look like and help to
answer key questions that Albertans may have about the costs and benefits of the plan. In addition,
the report will also seek to identify, assess, and propose possible mitigation strategies associated with
the establishment and ongoing operation of an APP. While this report may identify costs, benefits,
risk, and options, it does not contain any recommendations or endorsements relating to the creation
and operation of an APP; nor does it contain any opinion or recommendation in relation to the current
or future operation of the CPP.
Where appropriate, we have performed any analysis in this report that compares an APP to the CPP
on an equivalent basis to ensure the ability for an “apples to apples” comparison. For example, to
ensure comparability of the contribution rates, we have assumed that an APP will provide identical
benefits to the current CPP. We have used the same methodology as the CPP 31 Report to determine
contribution requirements under an APP. We have also presented our figures to the same level of
significance as those in the CPP 31 Report for comparative purposes, but this overstates the actual
degree of precision inherent in our calculations.

History and features of the CPP
Overview
The CPP was implemented in 1966 to provide retirement income support to working Canadians in
every province except Québec, which established the QPP to serve as its own counterpart to the
CPP. The CPP and QPP maintain agreements to administer benefits from a single source. In addition,
both plans maintain international social security agreements to ensure Canadians working
internationally maintain their CPP/QPP eligibility.
Participation in the CPP is compulsory for every Canadian employed or self-employed in a province
or territory outside Québec, as well as members of the Canadian Armed Forces and Royal Canadian
Mounted Police who are employed in Québec, subject to a number of specific and narrow exemptions.
CPP benefits are funded solely through contributions from employers, employees and self-employed
individuals, and investment earnings; they are not subsidized by government. Contribution rates and
benefits are calculated based on pensionable earnings and benefits are inflation-indexed annually
based on the Canadian Consumer Price Index. 3
In 1997, the CPPIB was established 4 and the funding of the CPP was changed from a “pay-as-you-
go” approach, where annual contributions were expected to fund in-year benefit payments, to a partial
funding approach, where the CPP collected contributions higher than in-year benefits, with the excess
contributions professionally invested and to be used in the future when annual benefit payments
exceed the annual contributions. The sustainability of the legislated contribution rate is tested every
three years through an actuarial valuation that projects contributions, benefits, and investments over
a long projection period. The latest actuarial valuation was completed as at December 31, 2021 (CPP
31 Report).
In 2016, the CPP was enhanced to provide Additional CPP benefits. These benefits provide a higher
target replacement ratio on pensionable earnings, and also increased the level of earnings that would
be considered pensionable. These enhancements are being implemented through increased
contributions phasing in between 2019 and 2025. Unlike the Base CPP benefits (benefits in effect
before the enhancements), where benefits are only partially pre-funded, these Additional CPP benefits
are expected to be fully pre-funded by contributions during working years. An actuarial valuation is
completed every three years. The latest actuarial valuation of the Additional CPP was as at December
31, 2021. There are legislated tests in place to ensure contributions are adequate to fund the benefits;
if contributions are not adequate, benefits will be reduced.
3
Morneau Shepell Handbook of Canadian Pension and Benefit Plans, 17th edition, LexisNexis Canada Inc., 2020, pp. 44-45 (MS
Handbook).
4
The CPPIB was incorporated by an Act of Parliament (The Canada Pension Plan Investment Board Act) in December 1997.
Base CPP overview
Contributions
The amount that employers and employees each contribute to the Base CPP is the same and is based
on a percentage of the employee’s wages (pensionable earnings) between the Year’s Basic
Exemption (YBE) and up to the YMPE, both of which are defined in the CPP Act and further explained
in the Glossary. 5 Employees’ contributions are deducted from their pay and remitted to the Canada
Revenue Agency (CRA) by their employers, together with the employer’s own contributions, on a
monthly basis. Self-employed persons contribute an amount equal to both the employer and the
employee shares.
CPP contributions become payable when a person reaches age 18 and remain payable until a person
reaches age 70, retires or dies. 6 The current Base CPP contribution rate is 4.95 per cent of
pensionable earnings (for employees and employers, or 9.90 per cent for self-employed persons). 7 In
2022 there were approximately 15.2 million CPP contributors who contributed approximately $61
billion in Base CPP contributions 8 . For comparison, we have estimated 2.3 million Albertans
contributed $10.1 billion to the Base CPP in 2022, extrapolating from the latest year for which
provincial figures are available (2020). 9
Benefits
The Base CPP provides a monthly lifetime pension at age 65 that is indexed to increases in the
Canadian Consumer Price Index on an annual basis. The pension benefit is determined using the
member’s contribution history relative to historical YMPEs. The maximum pension that a participant
can receive is equal to 25% of the five-year average YMPEs in the year of retirement ($1,288.33 per
month in 2023). Participants can start their pension with a reduction as early as age 60, or with an
increase as late as age 70. In addition to the lifetime pension, the Base CPP provides for benefits
upon disability or death.
Additional CPP overview

In 2016, the federal government introduced enhancements to the CPP, with the cooperation of the
participating provinces. 10 These enhancements can be divided into two parts:
1. The First Additional CPP increases the maximum retirement pension payable from 25% of the
five-year average YMPE to 33.33%. The benefit and associated increase in contributions are
being phased in between 2019 and 2023. The ultimate First Additional Contribution Rate will be
2% of earnings up to the YMPE, split evenly between employees and employers.
2. The Second Additional CPP increases the level of pensionable earnings by 14% over the current
YMPE. This new higher earnings limit will be referred to as the Year’s Additional Maximum
Pensionable Earnings (YAMPE). Benefits and additional contributions will be phased in over a
two-year period from 2024 to 2025. After 2025, the Second Additional CPP contribution rate will
be 8% of the earnings between the YMPE and the YAMPE, split evenly by employee and
employer.
Unlike the Base CPP benefits, the Additional CPP benefits are designed to be fully-funded.
5
The YMPE for 2023 is $66,600 while the YBE is $3,500. See https://www.canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-
tips-2022/canada-revenue-agency-announces-maximum-pensionable-earnings-2023.html and the CPP Act) , ss. 18-19.
6
CPP Act, s. 17.
7
See CPP Act, Schedule 1.
8
31st Actuarial Report, Canada Pension Plan, as at 31 December 2021, s. 1.
9
See https://open.canada.ca/data/en/dataset/f8ec9eb8-62d1-487b-83ff-4c407b6cb227.
10
Manitoba agreed to the changes subsequent to their introduction on June 20, 2016.
Key features of an Alberta Pension
Plan
This section provides information on the anticipated key features of an APP in the event that Alberta
proceeds with the withdrawal of Alberta from the CPP. This information includes the level of initial
benefits and the contributions needed to support those benefits. In addition, we discuss how potential
future changes to benefits and contributions may be implemented. Additional detailed analysis related
to this section can be found in the appendices.
Level of initial benefits

The exit of a province to create its own plan providing benefits comparable to the current CPP has
been contemplated under the CPP Act. Creating an APP that mirrors the CPP would ensure Albertans
receive the same benefits as they had before the establishment of an APP, while not adding additional
complexity to the administration of benefits when members also have contributions with the CPP
and/or QPP.
Changes to the CPP benefits are uncommon – the 2016 enhancements were the first major change
to CPP benefits since its introduction in 1966. Any amendment or enactment that affects the
substance of CPP contribution rates or benefits levels, or the operations of the CPP accounts or
CPPIB, requires the consent of two-thirds of the provinces with two-thirds of the population of all
included provinces.
The fact that future CPP benefits could be changed through a separate process poses a risk that the
benefits under an APP could become out-of-sync. One possible solution to ensure continued
alignment with CPP benefits is for Alberta to provide a mechanism within the enabling legislation for
an APP requiring the Province to consider adopting any changes made to the CPP benefits.
The analysis in this report is based on an APP with identical benefits to the CPP.
While differences in benefits between an APP and the CPP could create administrative complexities,
there may be opportunities for Alberta to consider how benefits could be improved to assist in different
policy objectives that have been important to Albertans and Canadians in the past and how Alberta’s
unique culture and associated policy goals could be reflected in design changes. While the QPP has
maintained the same level of retirement benefit (i.e., Base benefits of 25% of YMPE plus adopting the
same Additional benefits as the CPP), Quebec has adopted minor ancillary benefit differences.
How might benefits be changed in the future after the establishment of an APP?
Based on our analysis, as well as observing how the 2016 enhancement was adopted by the QPP,
Alberta could unilaterally amend or change an APP once it has been established without being
constrained by the Confederation consensus mechanism outlined in the CPP Act for making
amendments to that legislation. How Alberta decides to unilaterally amend or change an APP would
need to be outlined in its enabling legislation.

What would a sustainable APP contribution rate be?
As noted in the History and Features of the CPP section of this report, CPP contribution rates are
legislated. The current aggregate Base CPP contribution rate is 9.90% (evenly split between
employees and employers). This contribution rate is set by legislation and needs to be confirmed as
adequate based on triennial actuarial reviews. The CPP 31 Report confirmed that this rate is adequate
in the long run (that is the minimum contribution rate is equal or below the legislated rate). Similarly,
the CPP 31 Report confirmed that the First Additional CPP Contribution Rate of 2.00% and the Second
Additional Contribution Rate of 8.00% were adequate to fund the Additional CPP benefits.
Discussion Box 1: Contribution rates
Pay-as-you-go contribution rate – the contribution rate needed to balance total incoming
contributions each year with the outgoing benefit payments and expenses in that year. This rate will
increase with more retirees or fewer contributors. The pay-as-you-go rates do not take into account
any assets already accumulated (or level of pre-funding) and are provided as additional information
for reference only.
Minimum contribution rate – the contribution rate that is expected over the projection period to
balance the total incoming contributions plus the required portion of assets and investment income
with the outgoing benefit payments and expenses, without a shortfall in any year of the projection
period. This rate will remain stable over the projection period. The CPP is funded based on the
minimum contribution rate approach.
Initial contribution rates

As previously noted, the following contribution rate analysis is based on an APP that provides benefits
identical to the CPP. Our analysis is based on data and a model that starts with a December 31, 2021
valuation date and utilizes the same funding approach as the CPP, which targets to match the asset-
to-expenditure ratios of a Base APP at the end of the 13th and 63rd years of the projection (and to
match at the end of the later of the 53rd and 63rd years of the projection, or 2088 and 2098 for the
Additional APP). This approach is further explained in the section of Appendix C documenting
actuarial methods. Note that we have determined the minimum sustainable contribution rates for an
APP, whereas the legislated rates may be set above these rates in order to reduce the likelihood of
being revised upwards in the future due to unfavourable experience, which is consistent with the CPP
approach.
Base APP
After calibrating our actuarial model to the CPP valuation results 11, we have estimated the minimum
contribution rate needed to sustain the Base benefits under an APP. Although our model projects an
APP from the end of 2021, including the calculated asset transfer at that time, we have projected how
the initial asset transfer amount will evolve, as the transfer will take place in the future. Under our
projection (based on the projection of the future Alberta population, incoming contributions, outgoing
benefit payments and expenses), we estimate that approximately 53% of the CPP assets (an
estimated $334 billion) would be transferred to an APP if the asset transfer takes place on January 1,
2027.
In addition, we have estimated pay-as-you-go contribution rates for an APP, which highlights the
current difference in Alberta’s demographics versus the CPP.
11
Details of the model including data, methodology and assumptions used are described in Appendix C. We note that the minimum
contribution rate for a Base APP is 5.91% compared to 9.54% for the Base CPP as disclosed in the CPP 31 Report, and lower than the
9.9% legislated contribution rate.

Discussion Box 2: How dates are used in this report
Our model starts its projection from December 31, 2021 (i.e., the same day as the CPP 31 Report’s
valuation date) and our determination of contribution rates are as of this valuation date. However,
since the purpose of the report is to assess a possible future exit from the CPP, figures for the asset
transfer amount noted in this report are as of January 1, 2027 unless otherwise noted
Table 2 – Comparison of contribution rates for Base APP and Base CPP
Estimated Base APP Base CPP (from CPP 31 Report)
Minimum Contribution Rate 5.91% 9.54%
Pay-as-you-go Rate – 2027 7.86% 10.08%
Pay-as-you-go Rate – 2060 11.87% 12.01%
Target A/E Ratio 28.9 8.4
The 3.63% difference in the minimum contribution rate for the Base APP would provide an initial
annual savings of over $5 billion in 2027 in comparison to remaining in the CPP. On an individual
basis employees and employers would each have approximate full year savings of up to $1,425 per
employee. This individual savings estimate applies for individuals whose earnings are at or above the
estimated 2027 YMPE level; for those with lower incomes, the dollar savings will be proportionately
lower.
Chart 1 – Evolution of pay-as-you-go rates for CPP and APP throughout the projection period
14%
13%
APP CPP
12%
11%
10%
9%
8%
7%
6%
2022 2032 2042 2052 2062 2072 2082 2092

The Base minimum contribution rate for an APP is significantly lower than the CPP Base minimum
contribution rate due in large part to the size of the estimated initial asset transfer (discussed in more
detail later in this section). In addition, the current ratio of Alberta contributors to Alberta beneficiaries
is higher than that of the ratio of CPP contributors to CPP beneficiaries due to a younger population
and historically higher employment. As such, under an APP, we expect that the returns on the initial
assets will fund a significant portion of future benefits and, even under a reduced minimum contribution
rate, an APP will experience positive net in-flows (i.e., contributions will exceed benefit payments and
expenditures) over the short and medium terms, allowing for a quicker accumulation of assets under
an APP. However, we observe that, although the pay-as-you-go rate for a Base APP is initially lower
than that of the CPP, we expect this rate to catch up with the CPP pay-as-you-go rate based on the
assumptions used in this analysis, as the age-dependency ratio in the Alberta population would
eventually catch up with the rest of Canada.
We have also estimated the minimum contribution rate for the Base Residual CPP contribution rate if
an APP is set up and assets were transferred from the Base CPP. The following table compares the
estimated minimum contribution rates for a Base APP, the Base Residual CPP and the Base CPP.
Table 2a – Comparison of contribution rates for Base APP, Base Residual CPP and Base CPP
Estimated Base Estimated Base Base CPP (from CPP 31
APP Residual CPP Report)
Minimum Contribution Rate 5.91% 10.36% 9.54%
Pay-as-you-go Rate – 2027 7.86% 10.47% 10.08%
Target A/E Ratio 28.9 5.1 8.4
The CPP funding methodology provides a flexible funding framework where the minimum contribution
rate does not vary significantly due to one-time events. Our modelling demonstrates that it permits a
trade-off between lower contributions and a lower level of benefit security (i.e., 5.1 years of
expenditure coverage vs the current 8.4 years between the Residual CPP and the current CPP). As
previously mentioned, it sets the minimum contribution rate such that the asset-to-expenditure ratio is
equal in projection years 13 and 63.
Additional APP
The minimum contribution rates needed to sustain an Additional APP are summarized in the table
below. Similar to the Additional CPP, the Second Additional Contribution Rate is equal to four times
the First Additional Contribution Rate. These contribution rates are based on the projection of Alberta’s
future population and contributions to, and expenditures from, the Additional APP. Details of the data,
methodology and assumptions used are described below and in Appendix C.
Table 3 – Comparison of Additional APP/CPP minimum contribution rates

Estimated Additional APP Additional CPP from CPP 31
Report
First Additional Minimum 1.98% 1.97%
Contribution Rate
Second Additional Minimum 7.92% 7.88%
Contribution Rate
Target A/E Ratio 23.6 24.5
Due to the assumptions used in the analysis, over the long run, the Alberta population would be
projected to be similar to the CPP population. Based on the funding methodology of the Additional
CPP, the Additional APP contribution requirements are similar to those for the Additional CPP.

For the Additional CPP, benefits may potentially be adjusted if the legislated additional contribution rates
are insufficient to fully pay future expenditures. Since the First Additional minimum contribution rate and
the Second Additional minimum contribution rate are lower than the legislated First and Second
Additional CPP contribution rates of 2.00% and 8.00%, the benefits under an Additional APP are
considered sustainable over the long term.
Long term nature of the projection

Our model projects the revenue and expenditures of both the Base and Additional benefits under the
CPP and an APP over at least 75 years. Both the length of the projection period and the number of
assumptions used create a significant amount of potential uncertainty, and actual experience will likely
not evolve in accordance with the projections, in which case, the actual contribution requirements may
deviate (significantly) from those provided in this report. We have included sensitivity analysis to
measure the impact of various changes to the assumptions on the projected minimum contribution
rates to illustrate the potential variance in the minimum contribution requirements.
We note that the rates provided in this report are the minimum contribution requirements based on
our long-term projections starting in 2022. Similar to the CPP, Alberta could include a buffer when
determining the legislated contribution rates for an APP. This would take into account the uncertainty
of the results and reduce the likelihood of having to increase contribution rates in the future.
The minimum contribution rates determined in this report for an APP are based on the same
assumptions used in the CPP 31 Report – in essence, the assumption is that the Alberta long term
economic conditions and population growth will be the same as that for the rest of Canada (less
Québec).
Uncertainty of results
The key reasons that a Base APP may result in lower contribution requirements than the Base CPP
are the level of estimated initial asset transfer amount based on the provisions under the CPP Act,
Alberta’s younger population compared to the rest of Canada’s, and a relatively higher level of
employment and higher average wages than the rest of Canada when the CPP was last analysed.
There are risks to achieving and maintaining a lower cost plan for Albertans versus the CPP, which
include:
• The calculation of the initial asset transfer amount from the CPP to an APP;
• How Alberta’s economic and demographic profile changes relative to the rest of Canada’s over
time;
• How differences in an APP asset return versus the CPP will impact contributions and benefit levels
over time.

The calculation of the initial asset transfer amount from the CPP to an APP
A literal reading of the legislation (Section 113(2) of the CPP Act) as written implies that investment
returns should only be applied to CPP contributions, and not to benefit payments and CPP
administration costs. Applying this literal reading of the CPP Act would result in an unrealistically large
Base asset transfer figure of $637 billion as of December 31, 2021 (117% of Base CPP assets as of
that date), which our model projects to grow to approximately $747 billion (118% of Base CPP assets)
as of January 1, 2027. An alternate and reasonable interpretation is to apply investment returns to the
net cash flows of contributions less benefit payments and CPP administration costs. This alternate
interpretation has been used for the purposes of this report.
Appendix B provides details on the calculation (including the data used, additional analysis and
methodology) of the amount and the process for transferring assets from the CPP to an APP.
Based on our review of the requirements under the CPP Act, we have calculated the initial asset
transfer amount from the CPP to an APP using the following method:
(a) Total of all CPP contributions, up to effective date of split, in respect of employment (and self-
employment) in Alberta
PLUS
(b) Net investment returns, up to effective date of split, attributable to the contributions in (a) less the
amounts in (c) and (d)
MINUS
(c) Any benefit payments paid from the CPP that would not have been payable if an APP existed
MINUS
(d) A proportion of CPP administration costs, up to effective date of split in proportion to the
contributions made by Albertans versus total CPP contributions.
For the purposes of this calculation, we have considered net investment returns under (b) to be the
investment returns earned on the net contributions (contributions less benefits and investment
expenses). 12
This methodology should produce the same outcome as if each province had run its own individual
program account within the CPP since 1966 and earned the same annual returns (expressed as a
percentage of the asset base at the beginning of each year) as the CPP as a whole and shared in the
costs as described, while being able to borrow from the other provinces to cover any benefit payments
in excess of contributions.
Using publicly available sources, we obtained historical contributions and benefit payment information
attributable to Alberta, as well as CPP investment returns and administration costs. However, there
are certain deficiencies we identified in the Alberta contributions and disbursements including:
(i) The CPP Base benefit payments made to persons outside of Canada are only available on a total
basis and have not been attributed to the province where the individuals made the contributions.
As such, we have increased the Base benefit payments attributable to Alberta by these outside of
Canada payments in proportion to Alberta’s share of the CPP population. Additional CPP benefit
payments made to persons outside of Canada are assumed not to be material for the purposes
of this analysis.
12
The common definition of net investment returns is gross returns less investment expenses.

(ii) It is unclear whether the CPP contributions attributed to Alberta in the publicly available information
are based on CPP contributions deducted from employment in Alberta or CPP contributions made
by taxpayers in Alberta. As such, further refinements may be needed for an actual final calculation
to capture contributions with respect to contributions made by residents from other provinces who
were employed in Alberta when they made CPP contributions.
(iii) Similarly, we believe that the benefit payments attributed to Alberta in the publicly available
information are based on CPP payments made to Alberta residents. Additional refinements may
be needed for an actual final calculation to reflect the payments to individuals who migrated to or
from Alberta following retirement or who had a period of employment in Alberta.
The estimated Base asset transfer amount using historical cash flow information and adjusted based
on (i) above is $277 billion as at December 31, 2021. This figure represents roughly 51% of the Base
CPP assets as at that date. Based on the projected cash flow and assumptions used in our APP
model, we have extrapolated that the Base asset transfer amount as at January 1, 2027 – a potential
transfer date for an APP – would be $334 billion or 53% of the Base CPP assets.
The estimated Additional asset transfer amount using historical cash flow information is $2 billion as
at December 31, 2021. This figure represents roughly 16% of the Additional CPP assets as at that
date. Based on the projected cash flow and assumptions used in our APP model, we have
extrapolated that the Additional asset transfer amount as at January 1, 2027 – a potential transfer
date for an APP – would be $16 billion or 17% of the Additional CPP assets.
In order to account for the potential data deficiencies indicated above on the contributions and
benefits, based on our analysis of inter-provincial migration statistics publicly available, we have
calculated the Base APP minimum contribution rate using a lower and higher estimate of the initial
asset transfer amount ($), summarized in the table below.
Table 4 – Minimum Base contribution rate based on alternate estimated initial Base asset transfer
amounts
Lower Best Higher
estimate estimate estimate
Estimated initial asset transfer amount at December 31, 2021 $214 billion $277 billion $302 billion
Estimated initial asset transfer amount at January 1, 2027 $262 billion $334 billion $362 billion
Minimum Contribution Rate 6.90% 5.91% 5.53%
More information on the derivation of the higher and lower estimates can be found in the asset transfer
section of Appendix B.
Because the asset transfer amount relating to the Additional CPP is significantly smaller, similar
analysis on a higher and lower estimate has not been performed with respect to the asset transfer
from the Additional CPP as it would not affect the contribution requirements materially.

How Alberta’s economic and demographic profile changes relative to the rest of Canada over
time
In order to assess these risks, we have used our actuarial model replicating the CPP valuation to
calculate the minimum contribution requirements based on alternate scenarios for a Base APP and
an Additional APP. Some of the factors that describe how the future population will develop are
related. For example, if Alberta’s future economic growth is higher than the best estimate basis, it may
lead to higher real wage increases for the population, higher net migration into Alberta, and then to
higher fertility rates. Conversely, lower economic growth may lead to these factors resulting in a
smaller/lower paid population in the future.
Given the uncertainty in forecasting such a long period, in addition to the best estimate assumptions,
we have prepared results using two alternative scenarios that highlight the sensitivity of the results to
differences in assumptions regarding future outlook. These alternative projection sets encompass
assumptions that are generally more optimistic and more pessimistic than those of the Best Estimate
projections. These alternative scenarios focus more on the impact of economic growth and
employment.
The main population and APP demographic and financial results of the three projection sets are
presented below. As expected, the outlook for APP finances is closely linked to the size and age
distribution of the general population in Alberta as well as other factors such as yield on investments.
Table 5 – Summary results – Alternate population and economic growth scenarios

Lower Best Higher
Growth Estimate Growth
Base APP Minimum Contribution Rate 5.58% 5.91% 6.19%
Additional APP First Additional Minimum Contribution Rate 1.94% 1.98% 2.03%
Additional APP Second Additional Minimum Contribution Rate 7.76% 7.92% 8.12%
An explanation for the behaviour of the Base minimum contribution rate may be in order as Table 5
provides results which may seem counter-intuitive. Chart 2 below shows the pay-as-you-go
contribution rates for the three scenarios. In it, as expected, higher growth results in a lower long term
pay-as-you-go rate. However, because of the funding methodology used to determine the minimum
contribution requirements (which replicates the methodology used for the CPP), the projected assets
(and the future returns on those assets) in the year in which the target asset-to-expenditure ratio is
established has a more significant impact on the minimum contribution rate in the lower growth
scenario, resulting in a lower minimum contribution rate.
The results for Additional APP minimum contribution rates may benefit from explanation, as the higher
growth scenario produces the highest minimum contribution rates of the three scenarios. The key
reason for this is the valuation method used by the CPP which forces the asset-to-expenditure ratio
in 2088 and 2098 to be equal and with the highest expenditures projected, more assets need to be
accumulated and thus more contributions are required. Directionally, these results are consistent with
the sensitivity results shown for the Additional CPP in the CPP 31 Report.
Note that we have assumed the same asset return for each of the three scenarios based on a highly
diversified investment strategy that replicates the CPPIB approach. We observe that if an APP
investment framework includes a mandate to support Alberta economic growth (as the QPP does), it
could have resulted in different assumed asset returns for the three scenarios.

Chart 2 – Comparison of the Base APP pay-as-you-go rates based on different population/growth
scenarios
16%
15%
Best Estimate
14%
Higher Growth
13% Lower Growth
12%
11%
10%
9%
8%
7%
6%
2022 2032 2042 2052 2062 2072 2082 2092

Chart 3 – Comparison of the Additional APP pay-as-you-go rates (first rate) based on different
population/growth scenarios
7%
6%
Best Estimate
5%
Higher Growth
Lower Growth
4%
3%
2%
1%
0%
2022 2032 2042 2052 2062 2072 2082 2092
The Higher Growth scenario represents a future with higher economic growth and employment levels
while the Lower Growth scenario represents a smaller population and fewer workers earning less in
real terms when compared to the Best Estimate scenario. A summary of the main assumptions for
the three projection scenarios are included in Appendix C.
How differences in an APP asset return versus the CPP will impact contributions and benefit
levels over time
Under the CPP’s funding structure, Base benefits are not meant to be fully pre-funded but returns on
the pre-funding are needed to maintain a stable minimum contribution rate. In effect, investment
returns are needed in order to meet the benefit promises at the current contribution rate. Alberta
could change the approach to funding benefits by adjusting the level of prefunding. A discussion of
the appropriate funding approach could be considered in the implementation of an APP. However,
investment returns will impact the sustainable minimum contribution rate. The following table shows
the impact of variance in the investment returns on the estimated minimum contribution rate:

Table 6a – Sensitivity of contribution rates to future real investment return
Assumed Annual Future Minimum Contribution Rate (%) Change Relative to the Best
Real Rate of Return Estimate (%)
Base APP Best Estimate 5.91 --
(4.02% p.a.)
Lower Return 10.75 +4.84
(-1.60% p.a.) 13
Higher Return 1.65 -4.26
(+1.60% p.a.)
First/Second Best Estimate 1.98/7.92 --
Additional APP (3.62% p.a.)
Lower Return 2.84/11.36 +0.86/+3.44
(-1.20% p.a.)
Higher Return 1.40/5.60 -0.58/-2.32
(+1.20% p.a.)
Sensitivity of the contribution rates to assumptions used

In addition, we have provided the sensitivity of the minimum contribution rates for a Base APP and an
Additional APP for the individual assumptions under the Best Estimate scenario in Appendix C. Details
of the assumptions used for the sensitivity scenarios and the resulting impact on the contribution
requirements are included in Appendix C of this report.
Contribution rates under potential adverse scenarios

We are also providing results based on the same potential adverse scenarios covered in the CPP 31
Report to illustrate potential downside risks due to potential or emerging trends. These three potential
risks have also been modelled to assess the impact on the Base APP.
For the purposes of this report, we have used the same assumptions for the adverse scenarios as
those used in the CPP 31 Report although the impact of these scenarios on Alberta’s economy may
be quite different and may warrant different assumptions.
Table 6b – Sensitivity of contribution rates to potential adverse scenarios

Minimum Contribution Rate under Difference
Base APP
Best Estimate Assumptions 5.91%
Change in earners and earnings distribution 5.77% -0.14%
Stagflation 5.71% -0.20%
Green Economy Transition Scenario 1 5.80% -0.11%
Green Economy Transition Scenario 2 5.81% -0.10%
Green Economy Transition Scenario 3 6.32% 0.41%
For all of the potential adverse scenarios, except the Green Economy Transition Scenario 3, the
impact on the Base APP is directionally different than for the CPP. That is, for all but that scenario,
the contribution requirements for the Base APP will be lower in a smaller, lower growth Alberta
economy. This suggests that what may be an adverse scenario for the CPP may not necessarily be
an adverse scenario for the APP, as the size of the asset transfer relative to initial Base APP
expenditure offers some potential mitigation of future adverse outcomes; however, we also note that
the pay-as-you-go rates (which by definition ignore the asset transfer) would be higher in all of the
scenarios for the Base APP.
Further details of assumptions and results of these analysis have been included in Appendix C.
13
The values in parentheses represent the annual real return for the Best Estimate, and the difference in return from the Best Estimate
level for the Lower/Higher Return scenarios. These differences are consistent with the differences used in the high / low cost sensitivities
provided in Table 114 of the CPP 31 Report.

Actuarial methodology notes
Our approach
Forming the basis of the analysis, our model reproduces the projected minimum contribution rates of
the Base CPP and Additional CPP on both a pay-as-you go basis (contributions pay for benefits in
the year subject to a small reserve), and the CPP funding basis using publicly available demographic
information.
Details of our reproduction of the Base CPP and Additional CPP calculations compared to the results
disclosed in the CPP 31 Report are provided in Appendix C.
We then used publicly available Alberta demographic information to project the Alberta benefit
payments and estimate the Alberta minimum contribution rate of a Base APP and an Additional APP
on both a pay-as-you-go basis and the CPP funding basis. The minimum contribution rates shown
are based on the same assumptions for future projection as those used in the CPP 31 Report.
All minimum required contribution calculations in this report are prepared as at December 31, 2021 to
be comparable with those disclosed in the CPP 31 Report.
Subsequent event
The COVID-19 pandemic and increased worldwide uncertainty have impacted the global and
Canadian economies and populations. These events have had an impact on market returns, inflation
and unemployment rates on the economic front, immigration and mortality on the population front.
Whether a standalone APP will be impacted more or less significantly than the CPP will depend on
whether these events impact the Albertan population and economy more or less significantly than it
does the rest of Canada.
The projections in this report have not taken into account the potential future impacts of these events.

Process for withdrawing from the CPP
Under the CPP Act, a province can withdraw from the CPP if it meets the requirements outlined below.
The other provinces are not legally entitled to a formal role in the withdrawal process or a veto over
the withdrawal. In order to meet the prescribed withdrawal requirements, the replacing provincial plan
must:
1. Accept contributions beginning in the third year following the year in which the province gives
notice of its intention to withdraw from the CPP;
2. Provide comparable benefits to the CPP; and
3. Assume all obligations and liabilities accrued and accruing in the CPP for members residing in the
province up to the beginning of the third year following the year in which the province gives notice.
Note that the CPP Act requires the enacting legislation be in place at least one year before the
effective date of an APP.
Accept contributions beginning in the third year following the year of notice
For illustrative purposes, we use the example of the Province providing notification of withdrawal on
January 1, 2024 and being able to meet all of the above conditions. This withdrawal mechanism would
then mean that on January 1, 2027, the beginning of the third year following the year notice is
provided, an APP would come into effect for residents of Alberta (the APP Effective Date). On the
APP Effective Date, an APP would then assume responsibility for the payment of full benefits that
have been earned under the CPP for its residents (as well as being responsible for the portion of
benefits earned by contributors that were employed in Alberta when they made contributions to the
CPP prior to that date), and contributions for Alberta-based employment would be made to an APP
instead of the CPP. Note, we have been provided no timeline or indication that the province of Alberta
is pursuing this option. The notification date chosen was merely for illustration purposes.
Provide comparable benefits to the CPP

As noted in the above withdrawal procedure, a provincial pension plan must provide comparable –
but not necessarily identical – benefits to those provided by the CPP, including the Additional CPP
benefits. As a result, Alberta would have some flexibility in the design of an APP’s benefits, including
flexibility to provide benefits greater than the CPP. However, as has been previously noted, our
analysis is based on Alberta providing benefits identical to those under the CPP.
Assumption of obligations and liabilities

In following the CPP Act withdrawal process, Alberta would be required to assume responsibility for
paying the benefits associated with all contributions and benefits with respect to Alberta beneficiaries
under the CPP. Thereafter, an APP would be responsible for all the benefits that are attributable to
contributions made before the APP Effective Date in respect of employment in Alberta or in respect
of self-employed earnings of persons resident in Alberta along with the benefits earned (for
contributions made) after the APP Effective Date.

In conjunction with the assumption of all obligations and liabilities accrued and accruing in the CPP
for members making contributions in respect of Alberta employment, there would be a corresponding
asset transfer between the CPP and an APP. With respect to the Base APP, this asset transfer is
estimated at $334 billion as of January 1, 2027 (approximately 53% of the estimated Base CPP assets
available on that date). With respect to the Additional APP, this asset transfer is estimated at
$16 billion as of January 1, 2027 (approximately 17% of the estimated Additional CPP assets
available on that date). These estimated asset transfer amounts represent the cumulative excess
contributions made by Alberta employees and employers over the benefit payments made to Albertan
recipients along with investment returns less a proporationate share of expenses with respect to Base
CPP and Additional CPP respectively.
The CPP Act states that the CPPIB shall transfer Alberta provincial bonds and Canada federal bonds
and the balance in a manner that may be prescribed. There appears to be some latitude in terms of
how the asset transfer will actually take place, as in-kind transfers and even potential shares of illiquid
assets may be difficult to transfer. The actual form of the transfer will need to be negotiated and agreed
on.
Details of the calculation of the asset transfer amount, the data and methodology and additional
considerations are set out in Appendix B.
In the three years between notification and effective date, a number of activities need to take place to
ensure a smooth transition from the CPP to an APP. The following section discusses the activities
that need to be considered for a successful transition to an APP.

Transition considerations
On the basis of providing notification on a January 1st, the Province has three years from when it
notifies the federal government of its intent to withdraw from the CPP in order to implement this
seamless transition. It is critical that all the pieces needed to deliver an APP are identified and
implemented in advance of this deadline. This does not preclude the Alberta government from starting
implementation before providing notice.
To support a seamless transition, the key activities that need to be considered, the level of risk of
delivering within three years and the potential risk mitigations are presented in the table below.
Table 7 – Transition activities

Key Activity Level of risk in three Risk mitigations
year delivery
Develop framework for implementing Low - Priority of Province to develop
and delivering an APP (plan design, - Develop governance structure
investment management structure, and project plan
governance, service providers)
Draft legislation, negotiate CPP/QPP Legislation – Low - Legislation needs appropriate
agreements for coordinating legal support
benefits, and international social CPP/QPP agreements - Gauge level of Québec and
security agreements – Medium federal cooperation
- Review options for
International international agreements and
agreements – High prioritize by largest impact
Setup and implement service Medium to High – - Understand timing for
providers depending on service contribution and benefit
provider structure administration implementation
- Understand restrictions of
timing for existing providers
- Extend three year period by
either
o Notifying withdrawal from
CPP once service
providers are partially
implemented, or
o Phased transition from
current providers
Communicate with Albertans and Low to Medium - Understand key messages,
employers challenges to transition, and
develop plan to engage
stakeholders
These key activities will be discussed in more detail below.

Framework for implementing and delivering an APP
It is important to understand the structure, legislation, processes, and service providers that need to
be in place. The diagram below outlines how money flows through the system for the CPP. While an
APP may have some differences in processes and service providers, a structure needs to be in place
to support the same flows.
Image 1 – Requirements for managing an APP’s cash flows
Plan structure
The CPP’s contribution rates, benefit levels, and investment management structure, are governed by
the provinces through legislation enacted by the federal government. Agreement of two-thirds of the
provinces of Canada with two-thirds of the population of all included provinces is required to make
any changes to these items under the CPP.
For an APP, the Alberta Legislative Assembly would be responsible for enacting an APP and would
have authority over future amendments. This will be analogous to the QPP, where the Québec
legislative assembly has enacted the QPP and is solely responsible for plan design, benefit levels and
contribution rates. The QPP includes provisions mandating triennial actuarial reviews and a public
consultation on the state of the QPP every six years, to be conducted by the competent committee of
the legislature.

Enacting legislation
The enacting legislation would contain the legislated contributions rates for a Base APP and an
Additional APP, as well as the associated benefit levels, and the investment management structure.
It could also include the model for ongoing oversight, the creation of any new organizations required
to administer an APP, selection of any external service providers and the framework for making future
decisions on contribution and benefit levels.
Ongoing oversight
Since the Province would be responsible for an APP, there are some different structures for oversight
that could be considered, including:
• Full Government Oversight – the government would be responsible for plan design, the framework
for delivering an APP, and the ongoing administration. It would make decisions relating to
contribution rates, benefit levels, investment structure (which could still be arms length), and the
framework to collect contributions and make benefit payments. In addition, it would be responsible
for monitoring service providers, investment returns, and the ongoing administration of
contributions and benefit payments. The QPP operates under this sort of model.
• Mixed Government and Board Oversight – the government would be responsible for plan design
and developing the framework for delivering an APP. A separate board of directors would be
responsible for the ongoing administration, which would include monitoring service providers,
investment returns and the ongoing administration of contributions and benefit payments. The
legislation would provide the process for selecting the board of directors and their mandate.
Changes to future benefit or contribution levels

For the purposes of this report, we have assumed that an APP would provide the same benefits as
the current Base CPP and Additional CPP. However, there is the potential to make future changes to
benefits and/or contribution levels. Future changes may improve or reduce benefits or contributions.
To ensure that changes to benefits and their potential impact on future contribution requirements are
not subject to constant re-adjustment, the Province may consider building into the legislation a
process for public consultation or a referendum to approve major changes to benefit levels, although
any such limitations would be subject to the principle that the legislature may not bind a future
legislature. It would also be expected that a triennial actuarial review would be a part of the APP
enabling legislation and this may result in contribution rate or benefit changes.
Other legislation, CPP/QPP agreements, and international social security agreements

Other legislation
In addition to the enacting legislation, there are a number of pieces of legislation, including long-term
disability, workers’ compensation, and income support that include provisions for means
testing/benefit adjustments that make reference to CPP. This set of legislation would need to be
adjusted to account for an APP as well. While beyond the scope of this analysis, the enactment of an
APP would also cause other provinces as well as the federal government to review their legislation to
ensure coordination.
We believe that the amendments to other legislation would be considered technical and would not
affect the substantive operation of such other legislation or affect the amount of or security of benefits
payable to recipients of these programs.

CPP/QPP agreements
The CPP and QPP have an agreement in place to ensure that members who have made contributions
under both the CPP and QPP only receive one combined pension when they retire. This agreement
describes the rules in place to determine whether the CPP or QPP pays the benefit, a process for
transferring money between the two plans as needed, and agreements to share data between the two
plans for calculating/administering the payments.
To ensure that Albertans who participate in the CPP and/or QPP are able to receive one pension, an
agreement between a new APP and both the CPP and the QPP would have to be negotiated.
International social security agreements

The CPP and QPP have a number of international social security agreements with other countries.
Canada has 59 such agreements, 14 whereas Québec has 39. 15
These agreements provide for two main purposes:

1. They prevent a member from having to contribute to both the CPP (or QPP) and the international
social security program while they are working internationally, and
2. They account for the benefits earned under the CPP (or QPP) and international social security in
totality, which avoids potential lost benefits for members during this period.
Without an Alberta international Social Security Agreement (SSA) with a given foreign jurisdiction,
Alberta would have no control over the application of the social security legislation of that foreign
jurisdiction, and members of an APP could lose benefits they would otherwise be entitled to had they
remained in Alberta. The onus would be on Alberta to sign replacement agreements with these other
jurisdictions in order to provide benefits to Albertans in respect of service under an APP.
Service provider setup and implementation

To ensure a smooth transition to an APP, the service providers that are needed to support the ongoing
operation of an APP would need to be identified and implemented in advance of the first payments
being made on the effective date of an APP. The following section titled “Delivering an APP” provides
details on the service providers that would be needed, along with the options available, the cost of
implementation and the ongoing costs.
The service providers discussed are contribution remittance management providers, benefits
administrators, investment managers, actuaries, and auditors.
Communication with Albertans and employers

Transparent communication is key to a successful transition. It will be important that Albertans
understand the provisions of an APP, how it would be managed, and whom to contact about benefits
(starting pensions, reporting deaths, asking questions).
Similar to the above, the Province would need to communicate with employers of Alberta-based
employees, not just in Alberta, but across the country. Employers would need to know the contribution
levels for an APP, how contributions are collected, where employees can get information, and how
they would be impacted by international social security agreements.
Developing a strong communication plan that anticipates the needs and questions that Albertans and
employers will have is critical to a successful transition.
14
https://www.canada.ca/en/revenue-agency/services/tax/canada-pension-plan-cpp-employment-insurance-ei-rulings/international-social-
security-agreements-canada-pension-plan/what-purpose-international-social-security-agreements.html.
15
https://www.rrq.gouv.qc.ca/en/programmes/regime_rentes/ententes_internationales/Pages/ententes_internationales.aspx.

Delivering an APP
As discussed in the prior section, in order to ensure a smooth transition, a number of factors need to
be considered, including the service providers that will be needed to support an APP. This section
identifies the key service providers that would be needed to deliver an APP, along with possible
options and costs of implementation and ongoing costs.
Framework for implementing and delivering an APP

The diagram from the prior section showing how money flows through the system for CPP is shown
again below, and has been supplemented with commentary on the service providers that would be
required to support the system.
Image 2 – Requirements for managing an APP’s cash flows

In addition to the services noted in the above graphic, the CPP also receives:
• actuarial services from the Office of the Chief Actuary who advises on the design, funding and
administration of the CPP and is responsible for the content and actuarial opinions in its reports,
and
• audit services – these services include those performed by the Auditor General of Canada and by
independent auditors (in the case of the audit of the CPPIB).
We have provided additional analysis below on the different service providers that could be used to
deliver an APP, with the options mainly broken down into the following categories:
1. Utilize existing CPP providers – this would require service agreements and cooperation from the
federal government;
2. Utilize existing Government of Alberta resources such as the Tax and Revenue Administration
Division of ATBF (TRA) and existing Alberta service providers like Alberta Pensions Services
Corporation (APSC) and/or Alberta Investment Management Corporation (AIMCo) – this could
require changes to their mandates, systems, staffing and structure;
3. Create new Alberta public sector/independent service providers specifically for an APP; or
4. Utilize private sector service providers.
Contribution management
Employees and employers as well as self-employed persons will make contributions to an APP. These
contributions will need to be remitted, received and directed to the appropriate APP account to be
used for benefit payments or investing. Employers and self-employed people currently submit payroll
and income taxes directly to CRA, including employee and employer contributions to the CPP. A
process for collecting APP contributions would need to be developed.
Given the existing structure in place to collect taxes, we have only considered two options for
administering the withholding, remittance, enforcement and collection of contributions to an APP,
Option 1: CRA administers APP contributions or Option 2: TRA administers APP contributions. Based
on our analysis, setting up a new Alberta contribution management organization or engaging private
sector service providers were not feasible options and have not been considered.
Option 1: CRA administers APP contributions

Personal income taxes on Albertans are governed by the Alberta Personal Income Tax Act (APITA)
and are collected for the Government of Alberta by the CRA under a tax collection agreement between
the Government of Alberta and the Government of Canada (the Alberta Tax Collection Agreement).
The administration of contribution collection for an APP through the CRA is arguably a natural
extension of the services the Government of Canada is already providing to the Government of Alberta
under the Alberta Tax Collection Agreement. The current Alberta Tax Collection Agreement does not
contemplate an APP; consideration could be given to whether the existing Alberta Tax Collection
Agreement could be extended to include an APP or an agreement substantially similar to the existing
agreement could be negotiated with the Government of Canada.
The benefit to having the CRA administer an APP is that the current employer source deduction
system under the Income Tax Act (Canada) (the Federal ITA) identifies employers (through payroll
numbers) and employees (through social insurance numbers) and all relevant information to the
computation and collection of an APP is reported in the prescribed forms under the Federal ITA,
including the T4 – Statement of Remuneration Paid and T4 Summary (the T4 Reporting) that are
required to be provided on an annual basis to the CRA.

The T4 Reporting currently breaks down several forms of taxes, benefits and programs specific to
certain items including, for example, QPP contributions that are required in the Province of Québec.
While the Province of Québec collects QPP contributions directly, the information is broken down and
made available on the T4 Reporting requirements.
The costs associated with the administration by the CRA of an APP would likely include an
administrative fee, which is also imposed under the Alberta Tax Collection Agreement with respect to
the taxes covered by that agreement. However, there may be cost savings to the Government of
Alberta and employers of having the CRA administer an APP as it would be an extension to the current
source deduction system, including because the current system would not require employers to set
up additional payments directly to the Government of Alberta for an APP and the identification system
for taxpayers is established under the federal system. In this regard, the identification of persons on
whose behalf APP contributions should be made is directly tied to the existing tax administration
system in place in Alberta through the CRA and the federal tax identification numbers (whether
employer or individual) and would not require additional enforcement or investigation by the
Government of Alberta.
Option 2: TRA administers APP contributions

Currently, the ATBF is responsible for the administration of tax and revenue programs in Alberta. The
TRA is responsible for tax and revenue collection and administration.
The TRA collects Alberta corporate income tax directly from corporations doing business in Alberta
under the Alberta Corporate Tax Act and collects other types of Alberta taxes including, for example,
fuel and tobacco taxes.
The TRA does not currently have a system in place to directly collect personal income taxes from
employers (through payroll source deductions) or from individual Albertans. Such taxes are paid by
employers (through payroll source deductions) and by Albertans directly (in the case of self-
employment and business income) to the CRA. The APITA largely adopts the payroll source
deduction regime that is in place under the Federal ITA, including with respect to interest, fines,
penalties and enforcement mechanisms. The Alberta Child and Family Benefit program, which
provides direct financial assistance to lower and middle-income families with children under 18, is also
administered by the CRA on behalf of Alberta.
The scope of the Alberta Tax Collection Agreement Is limited to provincial taxes and would not cover
an APP.
The Government of Alberta could directly collect and administer contributions to an APP. In this
scenario, the Government of Alberta could explore a program similar to that of the Government of
Québec, which directly collects QPP contributions. Following this example, the Government of Alberta
would need to establish a platform through which employers and self-employed individuals could
report and remit the APP contributions. Supporting information, for purposes of individuals preparing
their tax returns, could be reported on the individuals’ T4 Reporting (similar to QPP amounts), but the
Government of Alberta would need to build the infrastructure to police and audit the system to ensure
employers are appropriately remitting the employer and employee contributions to an APP.
Public account considerations

With respect to the Public Accounts of the Government of Alberta, a number of legislative steps would
need to be undertaken in order to replicate existing reporting by the Government of Canada pertaining
to CPP assets and liabilities. The Government of Alberta could elect to establish different standards
of public reporting for APP purposes.

From a statutory perspective, CPP contributions remitted to the Government of Canada are deposited
in, and the benefits and expenses of the CPP are payable from, the Government of Canada’s
Consolidated Revenue Fund. The Government of Canada maintains a CPP Account and an Additional
CPP Account, to which amounts in respect of contributions received and amounts payable in
connection with CPP or Additional CPP benefits are credited and charged. The Public Accounts
include an accounting of CPP contributions, payments and outstanding liabilities, but do not
consolidate the assets and liabilities associated with the two CPP accounts, on the basis that these
funds are not controlled by the Government of Canada; the Public Accounts nevertheless provide
separate accounting of the assets and liabilities of the two CPP accounts.
If the Government of Alberta were to assume administrative responsibility for an APP, presumably it
would also establish an APP Account and possibly an Additional APP Account, to which it would credit
contributions received from employers and employees, and charge amounts payable in the form of
benefits or expenses associated with administering an APP. We would anticipate, in such a
circumstance, that the APP’s legislative framework would contain comprehensive public reporting
requirements relating to the revenues, payments, obligations, assets and investment performance.
Given that an APP would fall under the control of the provincial government, accounting standards
could allow (or require) for presentation of APP assets and liabilities on the province’s consolidated
financial statements. This would present a contrast to the CPP, as the Public Accounts of Canada
present CPP assets and liabilities separately, and not as part of the consolidated accounts. It may be
desirable for an APP’s legislative framework to address this issue and allow for separate presentation
of APP related assets and liabilities on the province’s consolidated financial statements for additional
public transparency.
In addition, an identification system is required to identify employers and self-employed persons in

Alberta for purposes of an APP. Currently, corporations in Alberta have an Alberta-specific tax
identification number that could be used for purposes of an APP. Individuals in Alberta do not have a
tax identification number specific to the province. Some form of identification system for Alberta
individuals would be necessary to ensure APP contributions are made. 16
Benefits administration
The benefits administrator is responsible for managing the personal information of members, sharing
of data with the CPP/QPP, calculation and payment of benefits and the overall plan member
experience. In addition to traditional pension benefits administration, the CPP has structures in place
to adjudicate disability benefits and resolve disputes and appeals of benefit decisions.
Employment and Social Development Canada (ESDC) is responsible for the administration of the
CPP. It uses Service Canada’s website/call center to provide information on the CPP, initiate the
payment of benefits and estimate a member’s pension (including income from other sources). In
addition, the Social Security Tribunal of Canada (which includes both a general and appeals division),
hears and makes decisions on appeals of decisions made by ESDC.
In Alberta, the APSC provides similar services to public sector plans in Alberta; however
administration of an APP includes additional elements not usually dealt with in registered pension
plan administration, including dealing with members who are self-employed, dealing with a number of
employers greater than in even multi-employer plans, adjudication of disability claims, and dealing
with payments to surviving children. These functions would need to be addressed in order to
administer an APP.
16
The Government of Alberta’s ability to rely on social insurance numbers for this purpose would have to be considered as part of the
implementation phase.

Options for an APP
The table below summarizes the options available and associated considerations for an APP.
Table 8 – Considerations for selecting benefits administrator

Option Considerations
Current CPP Provider - requires a service agreement with the ESDC
ESDC is responsible for the - the Province may have more limited influence on how an APP is
administration and payment of administered and the member experience
CPP benefits - allows members of an APP and the CPP to go to one source for
information
- the structure and expertise already exists within the ESDC to
administer an APP
- could continue to use Social Security Tribunal for appeals
- would require modifications to systems and processes
Existing Alberta Provider - APSC has an understanding of pensions, but social security programs
APSC provides administrative like an APP require additional expertise and systems, including ability
services to many of the large to adjudicate disability benefits and resolve claims disputes
public sectors plans in Alberta - the Province would have control over the member experience and
could use this as an opportunity to improve on the CPP member
experience
- potential for an integrated APP and public sector member experience
- would require a significant investment in structure, systems, staffing,
processes, and expertise
- would have to determine a procedure and venue for appeals
New Alberta Provider - similar considerations as for APSC
Create new public sector - would also require enacting legislation and additional setup costs to
provider to administer APP create operational infrastructure
benefits
Private Sector Provider - similar considerations as for APSC
Contract a private sector - would require a significant investment for implementation
provider to administer APP
benefits
Investment management and cash management

Employee and employer contributions in excess of benefit payments and expenses are invested to
reduce the long term cost of the plan and help pay for benefits when they exceed contributions. In
addition, money needs to be managed and moved between accounts to pay for benefits and
investments.
The CPPIB invests CPP assets and manages the flow of money between accounts. The CPPIB is an
independent organization that operates at arms-length to the federal and provincial governments. It
is not a crown corporation, and is governed by an independent board of directors appointed by the
federal government and the provinces that participate in the CPP. The CPPIB has a mandate to invest
in the best interest of CPP contributors, maximize return without taking undue risk, and provide cash
management services to the CPP to facilitate the payment of benefits.
For context, the mandate of the Caisse de dépôt et placement du Québec (CDPQ) with respect to
QPP investments is similar to that of the CPPIB in that it is to manage assets with a view to achieving
optimal returns, but the CDPQ mandate also includes a consideration to contributing to Québec’s
economic development.

Options for an APP
We have identified potential investment management models that the government of Alberta may
consider in determining how to hold the assets of an APP serving as a provincial counterpart to the
CPP. Each of these approaches would require purpose-drafted legislation or legislative amendments,
and engage unique governance considerations. Alberta could also consider whether the investment
management would report to a board that combines oversight responsibility for both the investment
and administration of an APP, or establish separate oversight for these functions.
The table below summarizes the options available for an APP and considerations.
Table 9 – Considerations for selecting investment manager

Current CPP Provider - requires a service agreement with the CPPIB and Canada (CPPIB unlikely
CPPIB currently invests to have authority to enter such an agreement on its own)
assets and supports cash - no transfer of assets would be required
management for the CPP - asset returns would be consistent with the CPP strategy
- limited amount of implementation should be required
- review oversight and structure from an APP perspective
- consider how cash would be managed if APP administrator is not ESDC or
CRA does not collect premiums
- APP mandate relating to CPPIB would likely need to be similar to CPP
Existing Alberta - AIMCo is a Provincial corporation
Provider - mandate would need to be expanded to permit investing for an APP
AIMCo currently manages - potential for over/under performance compared to CPP
assets for a number of - could consider additional measures to ensure independent operation
pension plans and other - could review cash management capabilities of AIMCo
Alberta government - would require an investment in structure, systems, staffing, processes, and
programs expertise
New Alberta Provider - mandate could be clearly aligned with APP investment objectives
Create new public sector - potential for over/under performance compared to CPP
provider to invest assets - could be designed for desired level of independence
and perform cash - could leverage AIMCo to achieve economies of scale and limit duplication
management for an APP of effort
- would require a significant investment for enacting legislation, structure,
systems, staffing, processes, and expertise
Private Sector Provider - not a model commonly employed by large public plans like an APP
Engage private sector - Alberta may consider this as a transition or supplemental approach to one
investment managers to of the alternate approaches above
manage assets and
perform cash
management for an APP
Actuarial services
The health of an APP will need to be measured on a regular basis through actuarial valuations. In
addition, other tests of the health of the plan or advice on the sustainability of benefits may be required
as well as analysis of Alberta specific population considerations (such as mortality, fertility, and
immigration). Alberta may consider consulting with the other public sector plans to have an Alberta
Chief Actuary also be responsible for the valuations for these other plans. Retraite Québec performs
this function for the QPP.

The Office of the Chief Actuary provides actuarial valuation and advisory services to the Government
of Canada. Included in these services is the ongoing valuation of the CPP at least every three years,
along with supplementary valuations if changes are considered or adopted (for instance when the
Additional CPP benefits were being considered).
Options for an APP

The table below summarizes possible options available for an APP.
Table 10 – Considerations for selecting actuary

Current CPP Provider - requires a service agreement with the Office of the Chief Actuary/Office of
The Office of the Chief the Superintendent of Financial Institutions and potentially Canada
Actuary currently provides - APP valuation may require unique assumptions compared to the CPP
actuarial valuation and - limited amount of implementation would be required
advisory service to the CPP
Existing Alberta Provider - there is no existing Alberta provider to consider
New Alberta Provider - mandate may not be large enough for a dedicated actuarial team, although
Create new public sector Retraite Québec performs this function for the QPP
provider to perform actuarial - could consider possibilities to expand mandate to other government
services programs like Workers’ Compensation Board or public sector pension
plans
- would require an investment for enacting legislation, structure, systems,
processes, and expertise
Private Sector Provider - this model is common for private and public sector pension plans
Contract a private sector - need unique expertise to provide these services for plans like an APP
provider to perform - competitive landscape is likely thin and would have significant transition
actuarial valuations and costs as any subsequently new provider would have to replicate previous
provide consulting services results and build valuation models
- would require implementation costs
Audit services
Oversight and audit is important for the transparent and compliant operation of an APP. The auditor
reviews financial statements and internal processes and controls.
Audit services for the CPP are provided by different service providers, including the Auditor General
of Canada, and independent external auditors. The Auditor General of Canada audits the financial
position of the CPP as it applies to Canada (and the participating provinces) while the CPPIB, as an
independent entity, retains a private audit firm for auditing its financial statements.
Options for an APP

The model for audit services will depend on the overall model for delivering services. There may be
opportunities to have certain services performed by the Auditor General of Alberta, with other services
being performed by independent external auditors.
The costs of operating and implementing an APP

Implementing and operating an APP would be a significant investment of time and money. Each of
the service provider options presented in this section would require different levels of ongoing costs
and initial investments for enabling legislation, hiring, real estate, operational set-up, software and
systems, and project management.

We have provided some ranges of ongoing and implementation costs for an APP based on similar
service providers to the CPP. In preparing our analysis, we have considered the costs of running the
CPP, and large public sector pension plans. As is common with pension plans, we have separated
investment costs from non-investment costs.
Investment costs
Ongoing investment costs are commonly expressed in basis points (0.01% increments) of the assets
under management. These costs are generally realized as a reduction to the gross investment returns
of the manager.
The following table summarizes the ongoing investment costs for CPP, and an average large pension
plan. Note that the CPP includes certain cash management activities that are not standard for
investment managers, which will result in higher costs.
Table 11 – Investment management costs

CPP Average large
pension plan
Investment costs in basis points 87 50
of assets under management 17
While these costs are a good indicator to the magnitude of investment expenses that an APP could
expect, there are some items to note:
1. CPP investment costs include operational costs, transaction costs, external investment
management fees and performance fees.
2. The CPPIB plays an additional cash management role which, all else being equal, would increase
its costs.
3. The asset mixes are not all directly comparable, and as such the investment/operational costs are
not directly comparable. Generally asset mixes with more illiquid assets like private equity,
infrastructure and real estate are more expensive to acquire and manage.
4. The ultimate investment costs for an APP will depend on a number of factors including the asset
mix, and investment managers.
Implementation costs
The cost to implement an APP’s investment management structure will vary significantly by the
desired asset mix and the investment management structure selected based on the options discussed
in this section. If the investment manager exists and has the required expertise, then the
implementation costs would be in the range of $75 million to $150 million. Whereas, if the investment
manager needs to be setup or requires significant adjustments to expertise and staffing, then the
transition costs will be much more significant and would be in the range of $750 million to $1,200
million.
17
All figures represent the three-year average from 2017-2019. Investment costs includes operating, transaction, and
management/performance fees, and anything else deemed “investment” costs in the applicable plan’s reports.

Non-investment costs
Included in non-investment costs would be contribution management, benefits administration,
actuarial services and audit services as described above. For social security programs like the CPP
and QPP, these types of costs are usually represented as basis points on the pensionable/covered
earnings and are counted against the contribution rate. The CPP’s annual non-investment costs
average approximately 12 basis points of pensionable earnings 18 (or approximately $612 million per
year) while the QPP reports costs of approximately seven basis points ($97 million).
Implementation costs
The cost to implement an APP’s non-investment structure will vary significantly by the service provider
structure selected. At the low-end, assuming an APP would fully leverage existing CPP providers, we
estimate that implementation costs would be approximately $100 million. At the high end, assuming
an APP would create new providers or leverage private sector solutions, implementation costs would
be approximately $1,000 million. If Alberta leverages existing Alberta providers, costs would be
somewhat lower than the high end implementation cost, but savings would be limited as additional
staffing, structure, systems, expertise and processes would still be required.
New jobs
If Alberta decides to leverage existing Alberta structures or create new ones to deliver an APP, then
an APP could create 1,500 to 2,000 long term jobs in addition to the (temporary) jobs needed for
implementation. These new jobs would not necessarily be based in Alberta. However, we would
anticipate many of the jobs would be Alberta-based, and the number of new jobs and their location
will be a function of the approach Alberta undertakes in implementing an APP. For instance, if Alberta
decides to maintain the CPP’s infrastructure (CPPIB, Office of the Chief Actuary (OCA), CRA, etc.),
this approach may not result in a significant increase in Alberta-based jobs. Further, if existing Alberta
providers are used, the increases will be lower as the organizational infrastructure (human resources,
leadership, etc.) will already be in place.
18
Figures represent three-year average of non-investment expenses over pensionable earnings in the period 2017-2019. Pensionable
earnings were calculated by dividing reported contributions for each year by the applicable contribution rate. CPP figures came from the
2019 and 2017 CPP financial statements:
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o https://epe.lac-bac.gc.ca/100/201/301/public_accounts_can/html/2018/recgen/cpc-pac/2018/vol1/s6/supp-pension-eng.html

Opportunities for additional analysis
This report contains information that has been prepared to assist the Province by providing detailed
analysis on the benefits, costs, and risks of creating an APP through the withdrawal from the CPP. As
noted, this report has been prepared using publicly available information, and there are opportunities
for the Province to consider additional analysis.
Perform additional analysis on asset transfer amount and minimum contribution rates
While we believe our estimates for an APP are reasonable based on the publicly available data, the
Province could attempt a more detailed analysis based on more refined data from the Office of the
Chief Actuary. This would include individual membership data, and a more accurate accounting of
contributions and benefits attributable to Alberta for the purposes of determining the asset transfer
amount.
Analyse service providers

In our report, we have presented an overview of the different service provider areas and options. To
help in its assessment of the available options, the Province could consider doing an analysis
between the capabilities of the current CPP service providers and the other available options. This
will help to better assess the effort and cost required to implement the different options.
Building a governance structure and a project plan

If the Province decides to create an APP, we believe a logical first step would be to decide on the
governance structure, the APP benefits, and the desired service providers. It will be important to
understand the key service providers as the Province builds out its next steps (contribution and benefits
administration, and investment management). This will allow the Province to develop a comprehensive
project plan focused on a destination. Earlier action would also provide more lead time to reduce the
risk of not having the structure in place when an APP goes live.
Review funding methodology

Our analysis of the APP minimum contribution rate was based on the same valuation methodology that
is used by the CPP, which sets the asset coverage ratio in year 63 of the projection equal to the year
13 asset coverage ratio. However, with such a large asset transfer amount at the start of an APP, the
Province could consider alternative funding methods that could lead to lower contribution rates while
maintaining benefit security.
Consider the logistics of an asset transfer

If the Province decides to use an investment manager other than the CPPIB, it will need to consider
how and over what period it will be reasonable for an asset transfer to take place. While fixed income
and public equities will be straightforward to transfer out of the CPPIB, illiquid assets like private
equity, real estate and infrastructure take an extended period to liquidate and also to invest in.
Engage with Canada and Québec

Coordination with the CPP and QPP will be key to the success of an APP, and the Province will be
able to learn additional details of the administration of contributions, benefits, investments, and inter-
plan agreements that will help ensure the success of an APP when it goes live.

Appendices

Glossary
Additional APP The portion of an APP that would replicate benefits provided by the Additional
CPP (as described in Appendix C.5 – Detailed CPP Provisions for Modelling)
APP A potential Alberta Pension Plan as described under the “Background” Section
of this report
APP Effective The first day of the third year following the year in which the notice was given
Date by Alberta to the Minister of Employment and Social Development that Alberta
has provided by law for the establishment and operation of a plan of old age
pensions and supplementary benefits comparable to those then provided by
CPP and for the assumption under that plan of all obligations and liabilities
accrued or accruing under the CPP with respect to Alberta beneficiaries
AIMCo Alberta Investment Management Corporation
APITA Alberta Personal Income Tax Act
APSC Alberta Pensions Services Corporation
ATBF Alberta Treasury Board and Finance
Base APP The portion of APP that would replicate benefits provided by the Base CPP (as
described in Appendix C.5 – Detailed CPP Provisions for Modelling)
CDPQ Caisse de dépôt et placement du Québec
CPP Canada Pension Plan
CPP 31 Report Actuarial Report for the Canada Pension Plan as at December 31, 2021,
prepared by the Chief Actuary of Canada
CPP Act Canada Pension Plan Act current to 2020-12-28 and last amended on 2020-03-
01 and Regulations thereto
CPPIB Canada Pension Plan Investment Board
CRA Canada Revenue Agency
ESDC Employment and Social Development Canada
Federal ITA Income Tax Act (Canada)
First Additional The First Additional Contribution Rate of the Additional APP/CPP applies to
APP/CPP earnings between the YPE and the YMPE to fund the additional pensions
Contribution Rate complementing the Base APP/CPP with respect to earnings up to the YMPE as
provided under the Additional APP/CPP.
OCA Office of the Chief Actuary
QPP Québec Pension Plan
Residual CPP Residual CPP means the CPP following withdrawal of Alberta covering
remaining provinces
SSA Social Security Agreement
Second The Second Additional Contribution Rate of the additional APP/CPP applies to
Additional earnings between the YMPE and YAMPE to fund pensions with respect to
APP/CPP earnings between the YMPE and the YAMPE provided under the Additional
Contribution Rate CPP/APP.
Target A/E ratio For Base CPP and Base APP, the target A/E ratio is the asset-to-expenditure
ratio in the 13th and 63rd projection years following the valuation date.
For the Additional CPP and Additional APP, the target A/E ratio is the asset-to-
expenditure ratio in the later of 2088 and 2098 or the 53rd and 63rd projection
years following the valuation date.
TRA Tax and Revenue Administration Division of ATBF
USS Understanding on Social Security
YBE Year’s Basic Exemption as defined under as defined under CPP, currently the
first $3,500 of earnings. This rate has not changed since 1997.
YAMPE Year’s Additional Maximum Pensionable Earnings as defined under CPP
YMPE Year’s Maximum Pensionable Earnings as defined under CPP

Appendix A: Additional considerations
for an APP
A.1 – Coordination between the CPP and APP
An APP would have to be designed to coordinate benefit payments for individuals who have service
under it, the CPP and potentially the QPP. We believe that the current framework for benefit payments
between the CPP and QPP could be extended to an APP, subject to modifications.
The chief basis for cooperation between the CPP and QPP is the Agreement to provide for the
payment of benefits to or in respect of dual contributors made the 30th day of January, 1975 (the
Agreement), but a number of other agreements are also in place to coordinate benefit payments. The
Agreement operates on the basis that someone who has contributed to both the CPP and QPP
(defined as a “dual contributor”) will receive a single pension based on their place of residence at the
time they apply for the primary CPP or QPP pension.
In other words, where the dual contributor’s usual place of residence at the time of the application is
outside of Québec, the pension will be payable under the CPP. Where the dual contributor’s usual
place of residence at the time of the application is Québec, the primary pension is payable under the
QPP.
This means that, for example, a person who contributed to the CPP for most of their career and then
moves to Québec prior to retirement would receive a pension under the QPP, provided they are a
dual contributor. The Agreement would have to be adjusted if an APP significantly diverged in design
from the CPP or QPP.
The paying jurisdiction receives from the other jurisdiction a portion of the benefit paid under the
Agreement, essentially on a pro rata basis based on the proportion of the individual’s contributions
attributable to both of the plans. Each jurisdiction delivers to the other as of the end of each month a
statement showing the amount of the individual benefits that it has paid during the month under the
Agreement. Each jurisdiction pays the other the amount owing for the month, as determined under
the Agreement, without interest.
When issuing its first cheque, the paying jurisdiction informs the beneficiary that the whole amount of
the benefit is attributable to contributions made under both plans.
A.2 – Participation in an APP

Employees under federal jurisdiction
We would anticipate that the same rules determining jurisdiction under the CPP and the QPP would
apply in respect of an APP. The general rule is that the CPP does not apply in relation to employment
in Québec. 19 With respect to self-employed earnings for a year, the CPP does not apply with respect
to a person who was resident in Québec at the end of the year, or who resided in Québec immediately
before the person ceased to be resident in Canada. 20
19
CPP Act, s. 4(1)(a).
20
CPP Act, ss. 4(1)(b) and 4(5).

A person is deemed to be employed in the province in which the establishment of their employer to
which they report to work (e.g., the individual’s office, factory or other place of employment) is situated.
Where the employee is not required to report for work at any establishment of their employer, they
are considered to be employed in the province in which the establishment of their employer from which
their remuneration is paid is situated. 21
Pursuant to section 4(2) of the CPP Act, federal civil servants and private sector employees in federal
works or undertakings (e.g., railways, telecommunications) would be subject to the CPP unless the
federal government comes to an agreement with the province providing a comprehensive pension
plan pursuant to section 4(3) of the CPP Act. Therefore, the CPP Act provides that the CPP would
continue to apply to federal civil servants and federally regulated employees unless the Alberta
government is able to conclude an agreement with the federal government similar to the 1966
Canada-Québec agreement.
We summarize the current situation as follows:
Table A.2.1 – APP/CPP participation by type of employee

Type of Employee CPP or APP Comments
Employees employed in Alberta outside of APP
federal works or undertakings
Private sector employees employed in APP, In the absence of agreement with the
Alberta in federal works or undertakings assuming federal government, CPP Act provides
Alberta that CPP would continue to apply
makes
agreement
with federal
government
Federal civil servants employed in Alberta APP, In the absence of agreement with the
who are not Canadian Forces or RCMP assuming federal government, CPP Act provides
Alberta that CPP would continue to apply
makes
agreement
with federal
government
Canadian Forces or RCMP CPP Assumes that Quebec precedent would
be followed.
Indigenous 22 persons with tax-exempt APP Subject to employer or employee opt-in,
income as described below
Indigenous employees with tax-exempt income

Earnings of Indigenous persons that are not included as taxable income under the Federal ITA are
automatically exempt under the CPP, unless there is an election made to participate in the CPP. This
election may be made by the employer in respect of all of its Indigenous employees or it may be made
by the employee. Furthermore, a self-employed Indigenous person with tax-exempt income may elect
to participate in the CPP.
Similarly, Indigenous persons with tax-exempt income in Québec may elect to participate in the QPP.
21
CPP Act, s. 4(4); Act Respecting the Québec Pension Plan, s. 7.
22
The CPP Act continues to use the term “Indian” to categorize Indigenous persons whose earnings are not included in computing
income for the purposes of the Federal ITA. We have used the term “Indigenous,” which may include First Nations, Métis, or Inuit peoples.

A.3 – Social Security Agreements
Both the CPP and QPP have SSAs with a number of international jurisdictions. These agreements
help determine coverage for individuals who are subject to the laws of both jurisdictions and preclude
double-coverage. They can also deal with employees temporarily located in the other jurisdiction in
order to prevent them having benefits under both plans. Totalization rules provide for the recognition
of service in the other country for eligibility for benefits. Each country continues to pay for its own
benefits.
Since the Canada-US SSA is likely to be the most significant SSA to Albertans, we have discussed
the Canada-US SSA below as an example of the impact of these SSAs.
Coverage rules
The Canada-US SSA stipulates that, except as otherwise provided in the agreement, a person’s work
can only be covered by the social security system of one country. 23 Accordingly, a person who would
otherwise be subject to the laws of both countries will be covered only under the system of the country
to which the work is attributed and will be exempt under the system of the other country. This rule
effectively precludes double coverage and double contributions with respect to the same period of
employment or self-employment.
A further exception applies to employees who work for a Canadian employer and are temporarily sent
to the United States (US) (or vice versa). The person continues to be subject to the laws of the sending
country in respect of their work in that last territory provided that the employment in the territory of the
other signatory is not expected to exceed 60 months. This means that a Canadian employee sent to
work in the US on a temporary basis would continue to contribute to the CPP (or QPP).
Where a person is required to work in the territory of the importing jurisdiction for intermittent periods
of short duration, each such period is considered a separate period for the purpose of the 60-month
continuation rule. 24 For example, if an employee were sent to work by a US employer at a branch of
the US employer in Canada, and if that employee commuted each day from their US home to the
Canadian place of work, that employee would continue to participate in the US social security plans,
with no limit on the amount of time that they worked in Canada.
Totalization rules
The totalization rules recognize, for the purpose of eligibility for benefits under the legislation of one
signatory, periods of coverage under the legislation of the other signatory. It is important to stress that
the Canada-US SSA and the Québec-US USS do not mandate the integration of benefits; the
totalization affects only the eligibility for benefits. In other words, each jurisdiction independently
calculates and pays its own benefits.
If a person is not otherwise entitled to the payment of a benefit because of insufficient periods of
coverage under the CPP, the entitlement to the benefit shall be determined by including, for each non-
overlapping calendar year that includes at least one quarter of coverage credited under US laws, one
year of coverage under the CPP. 25
23
Canada-US SSA, Article V.
24
Canada-US SSA, Article V, paragraph 2(b).
25
Canada-US SSA, Article VIII, paragraphs 1(a) and 2(b).

In the application of totalization with respect to the entitlement to US benefits, the Canadian (or
Québec) Agency is required to notify the US Agency of the years in which a person is credited with
coverage under the CPP (QPP) along with such other information as may be necessary to determine
the amount of the person’s benefit. 26 In the application of totalization with respect to the entitlement
to Canada (Québec) benefits, the US Agency is required to notify the Canadian (Québec) Agency of
the periods of coverage that a person has completed under US laws along with such other information
as may be necessary to determine the amount of the person’s benefit. 27
Consequences of no SSA
An SSA between Canada and another country applies only for purposes of the CPP. Similarly, an
SSA between Québec and another country applies only for purposes of the QPP. Should Alberta
establish an APP, neither the participants in an APP nor Alberta would benefit from the provisions of
the SSAs between Canada and other countries. Alberta, as Québec has done, would need to
negotiate its own SSAs with respect to an APP.
An Alberta employee who works in a country with which Alberta has no SSA may be required to
contribute, with respect to that period of employment, under the social security legislation of both
Alberta and that other country. For example, absent an SSA, there would no five-year rule allowing
continued coverage for international assignments. 28 In addition, such an individual would not benefit
from the totalization benefits provided under SSAs and could, as a result of working outside Canada,
lose benefit entitlements to which they would have been entitled had they remained in Canada.
A.4 – Comparison of the CPPIB Act and the AIMCo

Act
One of the options for investing the assets of an APP would be to assign this function to AIMCo or a
similar body as outlined above in the main report. This section provides a detailed comparison of
CPPIB and AIMCo including how they operate and the legislation governing these entities. The
purpose of this review is to illustrate some of the governance and structural decisions to be considered
in establishing a new investment manager or assigning the investment mandate to AIMCo.
The CPPIB was established pursuant to the Canada Pension Plan Investment Board Act (the CPPIB
Act). AIMCo was established pursuant to the Alberta Investment Management Corporation Act (the
AIMCo Act). Both are supported by corresponding regulations (respectively, the CPPIB Regulations
and the AIMCo Regulations).
This appendix summarizes the relevant provisions of the CPPIB Act and the AIMCo Act relating to
corporate governance and operational independence. The similarities and differences between the
legislative provisions are described briefly below and, where appropriate, are accompanied by some
observations regarding potential approaches the Government of Alberta could pursue in the event it
wished to align the governance structure of AIMCo (or another investment manager) more closely
with that of CPPIB.
26
Canada-US Administrative Arrangement, paragraph 6.
27
Canada-US Administrative Arrangement, paragraph 7.
28
Note, however, that Québec has provided a five-year rule in the second paragraph of section 8 of Regulation respecting pensionable
employment Act respecting the Québec Pension Plan.

Operational independence
Unlike AIMCo, CPPIB is explicitly not an agent of the Crown (CPPIB Act, s. 3(2)), and is not part of
the federal public administration (CPPIB Act, s. 3(3)). By contrast, AIMCo is explicitly identified as an
agent of the Crown (AIMCo Act, s. 3(1)) and is considered a Crown Corporation.
CPPIB is arguably subject to greater operational independence than AIMCo, as the AIMCo Act
establishes rights and privileges of the Minister (the President of Treasury Board and Minister of
Finance) relative to AIMCo, and corresponding obligations on the part of AIMCo. For example, AIMCo
must provide all records required by the Minister (AIMCo Act, s. 13(2)), disclose to a designated entity
information as directed by the Minister (AIMCo Act, s. 13(3)), and allow the Minister or a representative
access to all records and documents of AIMCo, including personal information as defined in the
Freedom of Information and Protection of Privacy Act for the purpose of reviewing and monitoring the
operations of AIMCo, administering the AIMCo Act and ensuring that AIMCo is carrying out the
purpose and intent of the AIMCo Act (AIMCo Act, ss. 13(4) and (5)). The Treasury Board may also
issue directives that must be followed by AIMCo or AIMCo’s board of directors (AIMCo Act, ss. 19
and 19.1). There are no analogous provisions in the CPPIB Act that allow the federal government
similar access to the records of the CPPIB or to issue directives to the CPPIB.
Observations: Whether, in practice, the Government of Alberta (through the Treasury Board) exerts
any influence over the operation or investment decision making of AIMCo, the AIMCo Act does contain
a number of provisions which allow for greater governmental involvement in its affairs than is available
to the Government of Canada under the CPPIB Act. If the Government of Alberta wishes to assert the
operational independence of AIMCo (or an equivalent investment manager) in respect of APP assets,
the Government of Alberta may consider amending the AIMCo Act to remove the information sharing
requirements and the ability of Treasury Board to issue directives to AIMCo, or as an alternative, to
limit the application of those provisions to AIMCo’s activities unrelated to APP asset management.
Institutional objects
The CPPIB’s statutory purpose is limited to assisting the CPP in meeting its obligations to its
contributors and beneficiaries, managing amounts transferred to it in the best interests of CPP
contributors and beneficiaries, and overseeing the investment of CPP assets, with a view to achieving
a maximum rate of return without undue risk of loss, having regard to the factors that may affect the
funding of the CPP (CPPIB Act, s. 5).
AIMCo has been established and is authorized to provide investment management services to
designated entities in accordance with an investment management agreement and/or as set out in
regulation (AIMCo Act, ss. 2(2) and 6) and is obliged to act in the best interests of designated entities
while doing so (AIMCo Act, s. 2(2.1)).
Observations: The AIMCo Act could be amended to distinguish between AIMCo’s current
responsibilities towards its existing (and prospective future) clients and its responsibilities in
connection with the investment of APP assets. Specifically, the AIMCo Act could identify investment
expectations and guiding principles relating to the risk/reward profile for the portfolio in aggregate (as
the CPPIB Act does), so as to provide a clear expression of the investment objectives imposed on
AIMCo (and a standard against which AIMCo’s decisions and outcomes can be measured).
Alternatively, if the administrator of an APP were to enter into a contractual arrangement with AIMCo
(following the model currently applied to the jointly governed public sector pension plans which are
statutorily required to rely on AIMCo for investment management), the AIMCo Act could be amended
to provide that AIMCo be responsible for meeting the investment objectives of its client as set out in
the applicable investment management agreement, consistent with existing AIMCo Act provisions.

Board of director composition
The CPPIB is managed by a board of directors consisting of twelve individuals (CPPIB Act, s. 7).
Directors are appointed to three year terms by the federal cabinet (CPPIB Act, s. 10(1)), with the prior
consultation of the provincial ministers responsible for the CPP (CPPIB Act, s. 10(3)). The CPPIB Act
does not contain requirements relating to necessary skill, experience or residency, although the
Minster of Finance is directed to consider, when making appointment recommendations to cabinet,
geographic diversity, the Board having a sufficient number of directors with proven financial ability or
work experience to assist the board in meeting its objectives, and the intention that no more than three
of the twelve directors reside outside of Canada (CPPIB Act, s. 10(4)). Directors may be removed by
the federal cabinet prior to the end of the appointed term for cause (CPPIB Act, s. 10(6)). Director
remuneration is as determined in the CPPIB’s by-laws (CPPIB Act, s. 10(10)).
AIMCo is managed by a board of directors consisting of eleven individuals appointed by the provincial
cabinet (AIMCo Act, s. 4(1)) and director remuneration is determined by the provincial cabinet (AIMCo
Act, s. 4(3)). Directors are appointed for terms not to exceed three years (AIMCo Regulation, s. 2(1)).
Individuals appointed to the AIMCo board are required to have a proven and demonstrated expertise
in investment management, finance, accounting or law or as an executive or director in a senior
publicly traded issuer (AIMCo Regulation, s. 5).
Observations: On balance, the requirements of the AIMCo Act and Regulation relating to director
competence are stronger than the corresponding provisions of the CPPIB Act, and as they do not
contain geographical restrictions or limitations on the recommendation or appointment power (e.g.,
the requirement to consider regional representation or a soft limit on the number of non-resident
directors), the AIMCo Act does not contain provisions (beyond the competency requirements)
arguably limiting the pool of capable director candidates. The AIMCo Act also does not contain a
provision permitting the removal of directors for cause during the term of an appointment; this
ostensibly promotes operational independence insofar as the government has limited ability to remove
directors mid-term, although it may be viewed as a failsafe availabe for use only in extraordinary
circumstances, and the inclusion of the provision in the CPPIB Act could be cited as justification for
the necessity and reasonableness of such a clause. For reasons of operational independence, the
Government of Alberta may consider extending to the board of AIMCo the ability to set its own
remuneration, as currently enjoyed by CPPIB.
Standard of care
Directors and officers of CPPIB are obliged to act honestly and in good faith with a view to the best
interests of CPPIB, and exercise the care, diligence and skill that a reasonably prudent person would
display in the same circumstances (CPPIB Act, s. 14(1)). A director or officer who has, or ought to
have by reason of profession or business a particular level of knowledge or skill is obliged to utilize
that knowledge or skill in discharging their duties (CPPIB Act, s. 14 (2)).
Directors and officers of AIMCo are also required to act honestly and in good faith with a view to the
best interests of AIMCo, and exercise the care, diligence and skill that a reasonably prudent person
would display in comparable circumstances (AIMCo Act, s. 11). The duty of care owed by AIMCo’s
directors and officers is not enhanced by the particular skills or experience of the director.

Observations: The Government of Alberta may consider enhancing the standard of care owed by
directors and officers by requiring directors and officers to utilize any knowledge or skill that such
director or officers possesses, or ought to possess, by reason of profession or business, in order to
align with the analogous provisions of the CPPIB Act. In view of the fact that the AIMCO Act and
Regulation establishes a higher standard of expertise for directors than the CPPIB Act (and applies
such standard to each director, rather than at an aggregate board level), there is presumably little risk
that imposing such a standard would result in different standards of care being applied to individual
directors based on their backgrounds, which may be a concern where directors (and officers) have
varying levels of skill or expertise as a result of their profession or training.
Conflicts of interest
The CPPIB Act contains detailed conflict of interest provisions, requiring the disclosure of any conflicts
a director or officer may have involving an interest as a party to a transaction or proposed transaction
with the CPPIB , or as a director of officer of, or person holding a material interest in any entity involved
in a transaction or proposed transaction with the CPPIB (CPPIB Act, s. 22(1)).
The AIMCo Act incorporates by reference the disclosure requirements of the Alberta Business
Corporations Act relating to transactions in which a director has an interest (AIMCO Act, s. 11.1).
Observations: The AIMCo Act presently incorporates strong disclosure requirements to identify and
address potential conflicts of interest, holding AIMCo directors to the same standards as directors of
Alberta-registered corporations (and ensuring that any changes to the Business Corporations Act
provisions apply with immediate effect to AIMCo). While the AIMCo Act could be amended to include
its own detailed conflict of interest provisions (modeled on either the CPPIB Act or Business
Corporations Act provisions), there does not appear to be a significant gap between the governance
requirements applicable to CPPIB and AIMCo in this context.
By-laws
CPPIB may make by-laws consistent with the CPPIB Act (CPPIB Act, s. 27(1)), and shall provide a
copy of such by-laws or an amendment to the by-laws to the Minister as well as the provincial
ministers responsible for the CPP (CPPIB Act, s. 28(1)). The by-laws are available for review by the
public (CPPIB Act, s. 28(2)).
AIMCo is authorized to enact by-laws governing the business and affairs of AIMCo, and the calling
and conduct of board and committee meetings, but such by-laws must be approved by the Minister
(AIMCo Act, s. 9). There is not a corresponding obligation under the AIMCo Act to make the by-laws
available for public review.
Observations: The Government of Alberta may consider whether, as a matter of operational

independence, the Minister ought to retain the ability to approve amendments to AIMCo’s by-laws. As
a matter of operational transparency, the Alberta government may consider whether AIMCo’s by-laws
are to be available to the public.

Financial reporting
The CPPIB is obligated to prepare quarterly financial statements (CPPIB Act, s. 39(6)), which are
delivered to the federal and provincial ministers responsible for the CPP and to the general public
(CPPIB Act, s. 50(1) and (2)). The CPPIB is also responsible for preparing an annual report, with
prescribed contents, that is to be made available to the federal and provincial ministers for tabling
before Parliament and made publicly available (CPPIB Act, s. 51). The annual report is required to
include information pertaining to CPPIB’s governance practices, the remuneration of directors and
senior officers and the results of a special audit or special examination (CPPIB Regulation, ss. 21-
22).
The AIMCo Act contains no analogous provisions (likely in part because the entities on behalf of which
AIMCo invests are subject to their own reporting duties).
Observations: Transparent reporting of APP investment results could either be the direct
responsibility of AIMCo (as in the CPPIB model) or the APP administrator (whether that be the
Government of Alberta or a third party administrator). If the Government of Alberta opts for the former
approach, the AIMCo Act would presumably be amended to include specific reporting obligations
similar to those imposed upon CPPIB with respect to frequency, content and manner of distribution.
Alternatively, if the Government of Alberta elects to make investment performance reporting the
responsibility of the APP administrator, the AIMCo Act would presumably be amended to ensure that
the APP administrator receives the necessary information on a timely basis to facilitate such public
disclosures (or that the investment management agreement between the parties contain such
provisions, if the specific details are to be left to the investment management agreement).
Public meetings
The CPPIB is obliged to hold public meetings every two years in each province to discuss the contents
of the annual report, and at least one director or officer is to be attendance in each public meeting
(CPPIB Act, s. 52). There is no analogous provision in the AIMCo Act to hold public meetings.
Observations: In order to replicate the CPPIB model, the AIMCo Act would need to be amended to
impose an obligation on AIMCo to prepare an annual report, and to hold public meetings on a rotating
basis in various cities and regions throughout the province.

Investment rules
The regulations to the CPPIB Act set forth both quantitative and qualitative limits relating to CPPIB
investments (CPPIB Regulations, ss. 11, 13, and 15-18) which are modeled on the investment rules
applicable to employment pension plans and contained in the Regulations made under the Pension
Benefits Standards Act, 1985. We would expect that the Government of Alberta would want to
consider similar guideposts for AIMCo in the investment of APP assets, unless its responsibility was
limited to investing APP assets in accordance with a statement of investment policies and procedures
established by the APP administrator (in which case the legislation governing the APP administrator
might likely include such investment parameters, which in turn would be reflected in the statement of
investment policies and procedures).
Miscellaneous provisions
The CPPIB is required to have two sub-committees, the Audit Committee and the Investment
Committee (CPPIB Act, s. 30(1)), each of which has specific duties assigned by the CPPIB Act (CPPIB
Act, s. 31 and 34). AIMCo has only one statutory sub-committee with specified functions and
responsibilities: the Audit Committee (AIMCo Act, s. 10) (although AIMCo also currently has in place
an Investment Committee, a Human Resources and Compensation Committee, and a Governance
Committee).
The CPPIB is obligated to prepare a statement of investment policies and procedures for the
investment of CPP assets (CPPIB Act, s. 35) that complies with stipulated requirements (CPPIB
Regulations, s. 8); there is no analogous requirement for AIMCo (which we understand relies on
statements of investment policies and procedures developed by its clients).
Observations: If AIMCo is extended authority to invest APP assets, presumably it would become
responsible for the development of a statement of investment policies and procedures, and the AIMCo
Act would need to be amended to provide parameters for the development of such a statement.
Alternatively, responsibility for the preparation of the statement of investment policies and procedures
could rest with the administrator of the APP, as is the case with registered pension plans (whether
that be the Government of Alberta or a third party administrator), in which case AIMCo’s responsibility
would presumably be limited to investing APP assets in accordance with the statement of investment
policies and procedures, consistent with its obligation to its existing clients.

Appendix B: Additional discussion of
asset transfer from CPP to an APP
Asset transfer to support transferred CPP obligations and liabilities
Under subsection 3(1)(b)(ii) of the CPP Act, in order to withdraw its participation in the CPP, the
comparable pension plan set up by withdrawing province must assume “[…] all obligations and
liabilities accrued or accruing […]” to the effective withdrawal date, namely, the third year following
the provision of the required notice. 29 Under section 113 of the CPP Act, once a regulation has been
made prescribing the withdrawing province as a “province providing a comprehensive pension plan,”
as of the date of that regulation, all obligations and liabilities accrued or accruing cease to be
obligations or liabilities in respect of employment and self-employment in the withdrawing province for
the purposes of the payment of CPP benefits. 30
The CPP Act requires the federal Finance Ministry to pay a prescribed amount to the government of
the withdrawing province. The amount to be transferred is calculated as follows, as of the date of the
regulation prescribing the withdrawing province as a “province providing a comprehensive pension
plan”: 31
The sum of:
(i) The total amount of all contributions credited to the CPP Account and the additional CPP Account
in respect of employment and self-employment in the withdrawing province; and
(ii) The net investment return of the CPPIB, and all interest accrued to the credit of the CPP Account
and the additional CPP Account that is derived from the contributions referred to in item (i) above;
Less the following:
(iii) The part of all amounts paid as or on account of benefits under the CPP that would not have been
payable if the withdrawing province been a “province providing a comprehensive pension plan”
before the establishment of the CPP (i.e., May 3, 1965); and
(iv) The portion of the administrative costs under the CPP Act, in proportion to the total amount of the
contributions referred to in item (i) above against the total amount of all contributions credited to
the CPP Account and the additional CPP Account.
Interpretation of asset transfer legislation

A literal reading of the legislation in the section above implies that investment returns should only be
applied to CPP contributions, and not to benefit payments and CPP administration costs. Applying
this literal reading of the CPP Act would result in an unrealistically large Base asset transfer figure of
$637 billion as of December 31, 2021 (117% of Base CPP assets as of that date), which our model
projects to grow to approximately $747 billion (118% of Base CPP assets) as of January 1, 2027. An
alternate and reasonable interpretation is to apply investment returns to the net cash flows of
contributions less benefit payments and CPP administration costs. This alternate interpretation has
been used for the purposes of this report.
29
CPP Act, s. 3(1)(b)(ii).
30
CPP Act, s. 113(1)(a).
31
CPP Act, s. 113(2).

The simplified interpretation of the legislation that was followed for the purposes of this report can be
summarized as follows:
The sum of the following:
(i) Total of all CPP contributions, up to effective date of split, in respect of employment (and self-
employment) in Alberta; and
(ii) Net investment returns, up to effective date of split, attributable to the contributions in (i) less the
amounts in (iii) and (iv);
Less the following:
(iii) Any benefit payments paid from CPP that would not have been payable if an APP existed; and
(iv) A proportion of CPP administration costs, up to effective date of split, weighted according to the
contributions in Alberta versus total CPP contributions.
This methodology should produce the same outcome as if each province had run its own individual
program account within the CPP since 1966 and earned the same annual returns (expressed as a
percentage of the asset base at the beginning of each year) as the CPP as a whole and shared in the
costs as described, while being able to borrow from the other provinces to cover any benefit payments
in excess of contributions.
This methodology has been applied to Base CPP and Additional CPP separately for the purposes of
determining the asset transfer amounts shown in this analysis.
Data used and calculation of asset transfer amount

Table B.1.a below presents a historical progression on a best estimate basis of the Base CPP assets
which would be transferrable to Alberta based on the CPP legislation referenced above.
Table B.1.a – Historical Base CPP and Alberta contributions, benefits, operating expenses and rates of
return ($million except where noted)
Year Base CPP Base CPP Alberta Share Base CPP Net Base Asset
Contributions Benefits Paid of Base CPP Nominal Rate of Investment Balance at Dec.
Paid in Alberta(1) in Alberta(2)(3) Operating Return(5)(6)(7) Income 31
Expenses(4)
1966 55 - 1 0.7% - 54
1967 60 - 1 4.3% 3 116
1968 65 1 1 5.1% 8 187
1969 71 3 2 5.6% 12 265
1970 75 7 2 6.2% 20 351
1971 81 11 2 6.5% 26 445
1972 89 16 2 6.8% 33 549
1973 101 21 3 6.8% 41 667
1974 127 30 3 7.0% 50 811
1975 157 45 4 7.2% 64 983
1976 189 64 5 7.6% 81 1,184
1977 222 83 5 7.8% 98 1,416
1978 262 106 6 7.9% 121 1,687
1979 317 130 7 8.3% 150 2,017
1980 377 159 8 8.7% 187 2,414
1981 457 193 13 9.4% 241 2,906
1982 498 243 13 10.0% 309 3,457
1983 507 300 12 10.4% 373 4,025
1984 538 354 14 10.7% 445 4,640
1985 592 417 14 10.8% 516 5,317
1986 626 485 14 10.9% 594 6,038
1987 671 631 17 10.9% 667 6,728

Year Base CPP Base CPP Alberta Share Base CPP Net Base Asset
Contributions Benefits Paid of Base CPP Nominal Rate of Investment Balance at Dec.
Paid in Alberta(1) in Alberta(2)(3) Operating Return(5)(6)(7) Income 31
Expenses(4)
1988 755 750 14 11.0% 749 7,468
1989 850 850 22 11.3% 854 8,300
1990 956 950 19 11.4% 958 9,245
1991 1,029 1,068 15 11.2% 1,046 10,237
1992 1,092 1,213 24 11.0% 1,134 11,226
1993 1,177 1,343 21 10.9% 1,229 12,268
1994 1,268 1,452 27 11.0% 1,355 13,412
1995 1,345 1,535 25 11.3% 1,524 14,721
1996 1,448 1,632 30 11.0% 1,628 16,135
1997 1,708 1,719 36 10.8% 1,763 17,851
1998 1,978 1,810 45 10.9% 1,976 19,950
1999 2,244 1,889 35 1.7% 346 20,616
2000 2,694 1,983 44 9.9% 2,100 23,383
2001 3,215 2,095 47 6.2% 1,501 25,957
2002 3,657 2,234 56 0.3% 80 27,404
2003 4,013 2,355 70 11.1% 3,169 32,161
2004 4,270 2,517 56 8.9% 2,972 36,830
2005 4,664 2,661 64 13.2% 5,043 43,812
2006 5,235 2,807 70 14.4% 6,540 52,710
2007 5,778 2,966 82 2.7% 1,474 56,914
2008 6,221 3,113 79 -14.2% (8,384) 51,559
2009 6,121 3,237 87 7.6% 4,065 58,421
2010 6,293 3,339 96 8.9% 5,375 66,654
2011 6,718 3,619 94 5.4% 3,713 73,372
2012 7,476 3,911 115 9.7% 7,347 84,169
2013 7,976 4,163 113 13.2% 11,441 99,310
2014 8,474 4,347 94 15.2% 15,506 118,849
2015 8,391 4,629 101 15.6% 18,935 141,445
2016 8,007 4,903 95 4.2% 6,035 150,489
2017 8,123 5,218 105 11.4% 17,400 170,689
2018 8,379 5,550 107 8.2% 14,173 187,584
2019 8,612E 5,939 105 12.4% 23,521 213,673
2020 8,095E 6,334 111 12.0% 25,840 241,163
2021 9,103E 6,650 124 13.8% 33,564 277,056
(1) Sources: ESDC CPP Contributors Reports. The 2019 - 2021 Alberta Base CPP contributions are assumed
to be the same proportion of total Albertan CPP contributions in each of these three years as the total Base
CPP contributions are to all CPP contributions in each of those years. The 2021 total Albertan CPP contributions
were assumed to be made at the same rate of 2021 total CPP contributions as Alberta’s three-year average
proportion of total CPP contributions over the period of 2018 to 2020.
(2) Sources: ESDC Special Tabulation Reports, HRSDC Special Tabulation Reports
(3) Includes an addition for Alberta’s estimated share of benefit payments made to individuals residing outside
of Canada
(4) Sources: ESDC Income Security Program Statistics Book 1999, ESDC Quarterly Financial Reports
(5) Source: CPP 31 Actuarial Valuation
(6) Results for years 1966 to 1998 are on a cost basis, while results for years 1999 to 2021 are presented on a
market value basis. The annualized rate of return for the years 1966 to 1998 calculated on a market value basis
is estimated to be 9.8%.
(7) Rates of return and investment income are net of all investment expenses of the CPPIB for the year 1999
and thereafter.

Chart B.1 – Comparison of Alberta and rest of Canada historical Base CPP net cash flow
6,000
4,000
Net cashflow ($ms)
2,000
-2,000
-4,000
-6,000
1966
1968
1970
1972
1974
1976
1978
1980
1982
1984
1986
1988
1990
1992
1994
1996
1998
2000
2002
2004
2006
2008
2010
2012
2014
2016
2018
2020
Year
Alberta net cashflow CPP excl. Alberta net cashflow
Table B.1.b below presents a historical progression on a best estimate basis of the Additional CPP
assets which would be transferrable to Alberta based on the CPP legislation referenced above. The
Additional contribution information for Alberta has been estimated by taking total Albertan CPP
contribution information and subtracting the amounts attributable to the Albertan Base CPP (as shown
in Table B.1.a). The Additional expenditure information for Alberta has been estimated by taking
Alberta’s estimated proportion of the total Additional CPP contributions and multiplying it by the total
Additional CPP expenditure figure for each year.
Table B.1.b – Estimated historical Additional CPP and Alberta contributions, benefits, operating
expenses and rates of return ($million except where noted)
Year Additional CPP Additional CPP Benefits Additional CPP Net Additional
Contributions Paid and Expenditures Paid Nominal Rate Investment Asset Balance
in Alberta(1) in Alberta(2) of Return(2)(3) Income at Dec. 31
2019 264 21 5.6% 7 250
2020 490 29 10.8% 55 766
2021 932 33 4.8% 61 1,726
(1) Sources: ESDC CPP Contributors Reports and CPP 31 Actuarial Valuation. The 2019 - 2021 Alberta
Additional CPP contributions are assumed to be the same proportion of total Albertan CPP contributions in each
of these three years as the total Additional CPP contributions are to all CPP contributions in each of those years.
(2) Source: CPP 31 Actuarial Valuation
(3) Rates of return and investment income are net of all investment expenses.
Our determination of the estimated asset transfer amounts is based on data compiled from a number
of different sources, described below.

CPP 31 actuarial valuation
The CPP 31 Report contains an actuarial valuation of the CPP as at December 31, 2021 and was
submitted to the Minister of Finance on November 14, 2022 by the Chief Actuary. The report contains
detailed historical information on the Base and Additional contributions, expenditures, investment
income and asset balances from December 31, 2021 dating back to the inception of the CPP in 1966.
Employment and Social Development Canada reports

Information from various ESDC reports was made available upon request to support the calculation
of the asset transfer amount. The information provided was extracted from multiple ESDC reports
relating to aggregate CPP contributions, net benefits, quarterly financial reports, and historical records
of income security statistics.
Statistics Canada
Data regarding interprovincial migration and Base CPP contributions and benefit payments made
outside of Canada was sourced from various publicly available datasets published by Statistics
Canada. This information was incorporated into the calculation of the Base asset transfer amount. It
has been assumed that interprovincial migration has not had a material impact on the development
of the Additional asset transfer amount.
Data limitations
The data sources listed in the section above did not contain enough information to calculate the asset
transfer amount with certainty. The best estimate figures shown in Table B.1.a and Table B.1.b
represent what we have considered to be a reasonable interpretation of the available data. Significant
limitations of the available data which could distort Alberta’s share of the overall cash flows include:
• Data to identify the impact of interprovincial migrants and interprovincial employees was not
available.
• Minor unexplained discrepancies between various data sources.
• Base CPP rate of return data for the years 1966 to 1998 was provided on a cost basis only.
• A breakdown by province of CPP operating expense figures was not available.
• A breakdown by province of CPP benefits owed to non-residents of Canada was not available.
Range of the asset transfer amount – Base CPP

The potential lower estimate and upper estimate of the Base asset transfer figure as at December 31,
2021 were calculated based on alternative cash flow datasets that were adjusted for possible
limitations present in the data up to December 31, 2021. The lower estimate of $214 billion was
estimated assuming contributions were 5% lower and expenditures were 5% higher for Alberta than
what is shown in Table B.1.a above. Our model projects this lower estimate to grow to approximately
$262 billion as of January 1, 2027. The upper estimate of $302 billion was calculated assuming
expenditures were 5% lower for Alberta than what is shown in Table B.1.a above. Our model projects
this upper estimate to grow to approximately $362 billion as of January 1, 2027.

Form of assets transferred
The transfer of amounts further to the withdrawal of a province from the CPP is to be effected primarily
by the transfer of bonds of the withdrawing province and, secondarily, by the transfer of federal
government bonds. Subsection 113(1)(b) of the CPP Act states that, “in the first instance and to the
extent necessary,” the federal government is to transfer securities of the withdrawing province that
are considered designated securities under section 2 of the CPPIB Act. “In the second instance and
to the extent necessary,” the government is to transfer securities of the federal government that are
designated securities under section 2 of the CPPIB Act, and by the payment of any balance then
remaining in any prescribed manner. No such prescription has yet been made. 32
Under section 2 of the CPPIB Act, a “designated security” is an obligation of the federal or a provincial
government (or the Crown in right of the province), whose principal and interest is guaranteed by that
government. Before April 1, 1998, a designated security had to be held by the erstwhile CPP
Investment Fund and meet certain prescribed conditions. On or after April 1, 1998, it had to be
purchased by the Minister of Finance under section 110 of the CPP Act or is purchased by the CPPIB
under section 6.1 of the CPPIB Act. 33
Asset withdrawal issues and asset transfer considerations in legislation

Section 113(b) of the CPP Act provides that, where a regulation has been made under subsection
3(2) of the CPP Act, that the Minister of Finance shall transfer to the government of the province which
is the subject of that regulation an amount calculated pursuant to section 113(2) of the CPP Act. Such
a transfer is to be conducted by (i) in the first instance and to the extent necessary for that purpose,
securities of that province, or of any agent of Her Majesty in right of a province, that are guaranteed
as to principal and interest by that province; (ii) in the second instance and to the extent necessary
for that purpose, securities of the Government of Canada, that are guaranteed as to principal and
interest; and (iii) by payment of balance as determined by regulation. If such a regulation is required
in the circumstances it should include the authority on the part of the Government of Canada to
complete all required transfers.
Any issues as to the valuation of the assets to be transferred would be a matter for negotiation
between the Government of Canada, the Government of Alberta, the CPPIB and potentially AIMCO
or any other APP investment manager. As the timeframe for such transfers is not mandated, and there
may be a desire to delay the transfer of some assets in order to avoid CPP liquidity issues or allow a
staged transfer of invested assets, a negotiated rate of interest may be required.
32
CPP Act, s. 113(1)(b).
33
CPPIB Act, s. 2.

Appendix C: Detailed APP financial
results and actuarial model
C.1 – Financial projections
The tables below provide detailed projection results with respect to an APP as at December 31, 2021.
All figures are shown in millions of dollars, except where otherwise noted.
Table C.1.1 – Base APP using CPP legislative contribution rate of 9.90%
Year Pay-as- Contributory Contributions Benefit Operating Net Assets at Yield on Asset /
you-go Earnings Expenditures Expenses Investment 31 Dec. Investments Expenditure
Rate Income Ratio
2022 6.8% 101,888 10,087 6,784 127 (25,216) 255,015 -9.0% 33.0
2023 7.2% 107,043 10,597 7,593 134 15,288 273,174 5.9% 32.8
2024 7.4% 112,683 11,156 8,189 140 16,369 292,369 5.9% 32.7
2025 7.5% 118,286 11,710 8,784 147 17,511 312,660 5.9% 32.8
2026 7.7% 123,528 12,229 9,385 153 18,717 334,068 5.9% 32.9
2027 7.9% 128,940 12,765 9,982 159 19,990 356,682 5.9% 33.1
2028 8.0% 134,596 13,325 10,595 166 21,335 380,581 5.9% 33.4
2029 8.1% 140,456 13,905 11,225 173 22,757 405,845 5.9% 33.7
2030 8.2% 146,847 14,538 11,877 180 24,260 432,587 5.9% 34.0
2035 8.7% 179,888 17,809 15,519 218 33,614 591,342 6.0% 35.7
2040 9.3% 216,437 21,427 19,951 260 45,664 802,216 6.0% 37.8
2045 10.0% 256,742 25,417 25,481 304 61,387 1,077,679 6.0% 39.8
2050 10.8% 303,045 30,001 32,502 355 81,783 1,434,840 6.0% 41.7
2055 11.5% 356,549 35,298 40,432 413 108,208 1,897,930 6.0% 44.6
2060 11.9% 421,355 41,714 49,553 482 142,691 2,502,677 6.0% 48.81
2065 12.2% 498,404 49,342 60,459 563 187,868 3,295,195 6.0% 52.0
2070 12.5% 590,131 58,423 73,285 659 247,205 4,336,543 6.0% 56.5
2080 13.0% 820,671 81,246 106,045 893 428,049 7,511,588 6.0% 67.8
2090 13.1% 1,146,529 113,506 148,988 1,216 744,351 13,069,328 6.0% 84.1
2100 13.2% 1,604,755 158,871 209,541 1,657 1,301,974 22,870,560 6.0% 104.7
Table C.1.2 – Base APP using minimum contribution rate of 5.91%

Year Pay-as-you- Contributory Contributions Benefit Operating Net Assets at Yield on Asset /
go Rate Earnings Expenditures Expenses Investment 31 Dec. Investments Expenditure
Income Ratio
2022 6.8% 101,888 6,022 6,784 127 (25,007) 251,159 -9.0% 32.5
2023 7.2% 107,043 6,326 7,593 134 14,919 264,678 5.9% 31.8
2024 7.4% 112,683 6,660 8,189 140 15,717 278,725 5.9% 31.2
2025 7.5% 118,286 6,991 8,784 147 16,546 293,330 5.9% 30.8
2026 7.7% 123,528 7,300 9,385 153 17,407 308,499 5.9% 30.4
2027 7.9% 128,940 7,620 9,982 159 18,302 324,281 5.9% 30.1
2028 8.0% 134,596 7,955 10,595 166 19,234 340,709 5.9% 29.9
2029 8.1% 140,456 8,301 11,225 173 20,204 357,817 5.9% 29.7
2030 8.2% 146,847 8,679 11,877 180 21,215 375,653 5.9% 29.5
2035 8.7% 179,888 10,631 15,519 218 27,298 476,902 6.0% 28.8
2040 9.3% 216,437 12,791 19,951 260 34,523 602,276 6.0% 28.4
2045 10.0% 256,742 15,173 25,481 304 43,268 754,203 6.0% 27.8
2050 10.8% 303,045 17,910 32,502 355 53,727 935,634 6.0% 27.2
2055 11.5% 356,549 21,072 40,432 413 66,169 1,151,666 6.0% 27.1
2060 11.9% 421,355 24,902 49,553 482 81,122 1,411,530 6.0% 27.1
2065 12.2% 498,404 29,456 60,459 563 99,177 1,725,326 6.0% 27.2
2070 12.5% 590,131 34,877 73,285 659 121,036 2,105,405 6.0% 27.4
2080 13.0% 820,671 48,502 106,045 893 179,720 3,126,279 6.0% 28.2
2090 13.1% 1,146,529 67,760 148,988 1,216 268,160 4,667,785 6.0% 30.0
2100 13.2% 1,604,755 94,841 209,541 1,657 404,651 7,048,801 6.0% 32.3

Table C.1.3 – Additional APP, First and Second Additional CPP contribution legislated rates of
2.00%/8.00%
Year First/Second First Second Contributions Expenditures Net Net Assets at Yield on Asset /
Additional Additional Additional Cash Investm 31 Dec. Investments Expenditur
Contribution Contributory Contributory Flows ent e Ratio
Rate Earnings Earnings Income
2022 1.5% 101,888 - 1,528 49 1,480 (199) 3,007 -7.7% 51.3
2023 2.0% 107,043 - 2,141 59 2,082 203 5,292 4.9% 71.7
2024 2.00% / 112,683 4,965 2,651 74 2,577 335 8,204 5.0% 87.6
8.00%
2025 2.00% / 118,286 9,825 3,152 94 3,058 501 11,764 5.1% 98.0
8.00%
2026 2.00% / 123,528 10,324 3,296 120 3,176 696 15,636 5.1% 100.6
8.00%
2027 2.00% / 128,940 10,795 3,442 155 3,287 898 19,821 5.1% 99.8
8.00%
2028 2.00% / 134,596 11,316 3,597 199 3,399 1,117 24,336 5.1% 97.3
8.00%
2029 2.00% / 140,456 11,803 3,753 250 3,503 1,352 29,191 5.1% 93.9
8.00%
2030 2.00% / 146,847 12,401 3,929 311 3,618 1,605 34,414 5.1% 90.3
8.00%
2035 2.00% / 179,888 14,694 4,773 775 3,999 3,152 66,186 5.1% 72.8
8.00%
2040 2.00% / 216,437 17,058 5,693 1,638 4,056 5,697 108,721 5.6% 58.1
8.00%
2045 2.00% / 256,742 18,488 6,614 3,078 3,536 8,712 165,000 5.6% 47.7
8.00%
2050 2.00% / 303,045 19,501 7,621 5,344 2,277 12,398 233,493 5.6% 39.6
8.00%
2055 2.00% / 356,549 25,063 9,136 8,456 680 16,801 315,215 5.6% 34.3
8.00%
2060 2.00% / 421,355 32,117 10,996 12,585 (1,589) 21,992 411,339 5.6% 30.3
8.00%
2065 2.00% / 498,404 38,399 13,040 17,706 (4,666) 27,967 521,750 5.6% 27.8
8.00%
2070 2.00% / 590,131 45,796 15,466 23,430 (7,964) 34,835 648,781 5.6% 26.3
8.00%
2080 2.00% / 820,671 65,272 21,635 37,573 (15,937) 51,923 964,941 5.6% 24.6
8.00%
2090 2.00% / 1,146,529 93,344 30,398 55,242 (24,844) 75,315 1,398,819 5.6% 24.4
8.00%
2100 2.00% / 1,604,755 133,506 42,776 78,789 (36,013) 108,630 2,017,580 5.6% 24.7
8.00%

Table C.1.4 – Additional APP, First and Second Additional minimum contribution rates of 1.98%/7.92%
Year First/Second First Second Contributions Expenditure Net Cash Net Assets at Yield on Asset /
Additional Additional Additional s Flows Investment 31 Dec. Investments Expenditur
Contribution Contributory Contributory Income e Ratio
Rate Earnings Earnings
2022 1.5% 101,888 - 1,528 49 1,480 (199) 3,007 -7.7% 51.3
2023 2.0% 107,043 - 2,141 59 2,082 203 5,292 4.9% 71.7
2024 1.98% / 112,683 4,965 2,651 74 2,577 335 8,204 5.0% 87.6
7.92%
2025 1.98% / 118,286 9,825 3,115 94 3,022 500 11,726 5.1% 97.7
7.92%
2026 1.98% / 123,528 10,324 3,259 120 3,139 693 15,558 5.1% 100.1
7.92%
2027 1.98% / 128,940 10,795 3,403 155 3,247 893 19,698 5.1% 99.1
7.92%
2028 1.98% / 134,596 11,316 3,556 199 3,357 1,109 24,164 5.1% 96.6
7.92%
2029 1.98% / 140,456 11,803 3,710 250 3,460 1,342 28,966 5.1% 93.1
7.92%
2030 1.98% / 146,847 12,401 3,884 311 3,573 1,592 34,131 5.1% 89.6
7.92%
2035 1.98% / 179,888 14,694 4,718 775 3,944 3,122 65,533 5.1% 72.1
7.92%
2040 1.98% / 216,437 17,058 5,628 1,638 3,990 5,636 107,530 5.6% 57.4
7.92%
2045 1.98% / 256,742 18,488 6,538 3,078 3,460 8,608 163,021 5.6% 47.1
7.92%
2050 1.98% / 303,045 19,501 7,533 5,344 2,189 12,237 230,417 5.6% 39.1
7.92%
2055 1.98% / 356,549 25,063 9,031 8,456 575 16,559 310,610 5.6% 33.8
7.92%
2060 1.98% / 421,355 32,117 10,870 12,585 (1,715) 21,637 404,611 5.6% 29.8
7.92%
2065 1.98% / 498,404 38,399 12,890 17,706 (4,816) 27,457 512,101 5.6% 27.3
7.92%
2070 1.98% / 590,131 45,796 15,288 23,430 (8,142) 34,114 635,142 5.6% 25.7
7.92%
2080 1.98% / 820,671 65,272 21,386 37,573 (16,186) 50,525 938,549 5.6% 24.0
7.92%
2090 1.98% / 1,146,529 93,344 30,049 55,242 (25,194) 72,687 1,349,261 5.6% 23.6
7.92%
2100 1.98% / 1,604,755 133,506 42,284 78,789 (36,505) 103,790 1,926,388 5.6% 23.6
7.92%
Sensitivity analysis
The results of our sensitivity analysis is summarized in the following two tables. Our sensitivity analysis
adjusts each of the indicated assumptions up or down (the specific adjustments are outlined in table
C.4.4), while leaving the other assumptions the same. This will allow the user to understand the impact
each of these assumptions have on the results, in isolation. We caution the user that there may be
interaction among the various assumptions, so the actual impact on the minimum contribution rate
from a series of adjustments to the assumptions may not equal the simple addition of these individual
sensitivity results.
Table C.1.5 – Sensitivity of the Base APP contribution rates to individual assumptions
Assumption Scenario Minimum Change relative Pay-as-you-go Rates
contribution rate to the Best (%)
(%) Estimate (%) 2025 2060
Best Estimate 5.91 7.55 11.87
1. Total Fertility Rate Lower Cost 5.80 -0.11 7.55 11.29
Higher Cost 6.02 0.11 7.55 12.54
2. Mortality Rates Lower Cost 5.55 -0.36 7.55 11.47
Higher Cost 6.27 0.36 7.55 12.28
3. Net Migration Rates Lower Cost 5.83 -0.08 7.55 12.90
Higher Cost 5.99 0.08 7.55 10.96
4. Price Increases Lower Cost 5.67 -0.24 7.59 11.56
Higher Cost 6.15 0.24 7.51 12.21
5. Real Wage Increases Lower Cost 5.12 -0.79 7.64 13.03
Higher Cost 6.70 0.79 7.46 10.86
6. Future Investment Returns Lower Cost 1.65 -4.26 7.55 11.87
Higher Cost 10.75 4.84 7.55 11.87

Table C.1.6 – Sensitivity of the Additional APP contribution rates to individual assumptions
Assumption Scenario First Additional Second Additional Change Relative to
Minimum Minimum Contribution the Best Estimate (%)
Contribution Rate Rate (%)
(%)
Best 1.98 7.92
Estimate
1. Mortality Rates Lower Cost 1.90 7.60 (0.08) / (0.32)
Higher Cost 2.05 8.20 0.07 / 0.28
2. Price Increases Lower Cost 1.93 7.72 (0.05) / (0.20)
Higher Cost 2.03 8.12 0.05 / 0.20
3. Real Wage Lower Cost 1.82 7.28 (0.16) / (0.64)
Increases Higher Cost 2.15 8.60 0.17 / 0.68
4. Future Lower Cost 1.40 5.60 (0.58) / (2.32)
Investment Higher Cost 2.83 11.32 0.85 / 3.40
Returns
Inter-valuation Investment Experience

The CPP31 report includes an assessment of the impact of higher and lower levels of investment
returns over a short period on the contribution requirements of the CPP.
Base APP
Under the Base CPP, results are shown assuming asset returns had been higher or lower than the
actual returns during the inter-valuation period resulting in asset values at December 31, 2021 being
10% or 20% higher or lower than the actual value of assets for the Base CPP. We have replicated
this sensitivity scenario for the Base APP by assuming the asset value for the Base APP would be
10% or 20% higher or lower than the assets assumed in the best estimate scenario. The table below
shows the contribution requirements based on different levels of assets as at December 31, 2021
while under best estimate population growth assumptions.

Table C.1.7 – Sensitivity of the Base APP contribution rates based on different asset values
as at December 31, 2021
Assets at 31 Dec 2021 ($ billion) Minimum Contribution Difference
Rates
20% lower $222 6.78% 0.87%
10% lower $249 6.35% 0.44%
Actual $277 5.91% 0.00%
10% higher $305 5.48% -0.43%
20% higher $332 5.04% -0.87%
As expected, lower asset values result in increased contribution requirements while higher asset
values result in decreased contribution requirements.
Additional APP
Since the Additional CPP is still in its early years, the asset value under the Additional CPP is small
and thus different levels of assets as at December 2021 do not have a material impact on the First
and Second Additional Minimum Additional Contribution Rates. The CPP 31 Report illustrates the
estimated impact on contribution levels under the Additional CPP based on different levels of assets
as at December 31, 2045, by assuming a temporary deviation from the assumed asset returns in 2043
to 2045. We have prepared the sensitivity for Additional APP using these same parameters, while
maintaining all other assumptions in line with best-estimate assumptions of this report.
Table C.1.8 – Sensitivity of the Additional APP contribution rates based on different asset
values as at December 31, 2045
Projected Assets at Assumed Asset First / Second Additional Difference
31 Dec 2045 Returns 2043- Minimum Contribution Rates
($ billion) 2045
20% lower $132 -2.2% 2.12% / 8.48% 0.14% / 0.56%
10% lower $148 1.9% 2.04% / 8.16% 0.06% / 0.24%
Actual $165 5.6% 1.98% / 7.92%
10% higher $181 9.2% 1.92% / 7.68% -0.06% / -0.24%
20% higher $198 12.5% 1.86% / 7.44% -0.12% / -0.48%
Investment experience also has predictable effects on contribution requirements for the Additional
APP – lower asset amounts in 2045 result in increased contribution requirements while higher asset
amounts in 2045 result in lower contribution requirements.
Adverse Scenarios
The CPP 31 Report includes an assessment of downside risks on the Base CPP due to potential or
emerging trends. These three potential risks have also been modelled to assess the impact on the
Base APP. We have used the scenarios from the CPP 31 Report unadjusted.

Table C.1.9 – Description of adverse scenarios
Scenario Description of Scenario and Assumptions
1. Change in earners
Instead of assuming that all earners have the same 2.9% average wage increase
and earnings
distribution each year, three different wage levels are assumed to have different rates of
increase between 2022 and 2045:
• Low (up to 75% of average earnings) – 1.5%
• Medium Low (75% to 150% of average earnings) – 2.6%
• High (+150% of average earnings) – 3.5%
2. Stagflation • High levels of inflation continue for several years gradually declining to the
best estimate rate of 2% in 2032.
• Unemployment rates increase through 2028 then gradually decrease to best-
estimate rates in 2034.
• Wage increases are higher than under best-estimate assumptions but not to
the full extent of the extra inflation.
3. Green Economy
Reduced nominal GDP in 2030, 2050 and 2100 relative to best estimate
Transition–- 3
different scenarios assumptions with reduced GDP achieved by lower real wage growth without any
change in employment. Scenario 1 is assumed to have the least economic impact,
Scenario 3 the greater long-term economic impact while Scenario 2 has the worse
impact up to 2050, but less economic impact than Scenario 3 in 2100.
Asset returns are assumed lower in all three scenarios.
Following are the Minimum Contribution Rate requirements for the five downside risk scenarios
described above.
Table C.1.10 – Contribution Rates of the Base APP under various adverse scenarios
Scenario Minimum Contribution Difference
Rate
Best Estimate 5.91%
Change in earners and earnings distribution 5.77% -0.14%
Stagflation 5.71% -0.20%
Climate Change - Scenario 1 5.80% -0.11%
Climate Change - Scenario 2 5.81% -0.10%
Climate Change - Scenario 3 6.32% 0.41%
An explanation of how these scenarios impact the APP differently from the CPP has been included
in the report following Table 6b.

Actuarial opinion
• The data used for the calculations in this report are based on publicly available sources, and
available only in aggregated form. In our opinion, the data on which the calculations are based
are sufficient and reliable based on the terms of the engagement for this report.
• In our opinion, the assumptions used for the purpose of the calculations are reasonable and
appropriate, both individually and in aggregate.
• In our opinion, the methods employed for the calculations are appropriate for the purpose of the
report.
• The calculations included in this report and the actuarial information provided have been prepared,
and our opinions given, in accordance with accepted actuarial practice in Canada.
[Redacted to protect privacy - Original signed]
August 2023
Date
August 2023
Date

C.2 – Data for actuarial model
Population data
The data required for the valuation of an APP are extensive. As of December 31, 2021, required data
include the Alberta population, the distribution of earnings among the employed population, and the
distribution of benefits in payment, all segregated by age and sex. Specific assumptions such as the
distribution of retirement by age, and collection of contributions are determined with reference to the
application of the CPP provisions and historical experience.
Below is a summary of the data used in our analysis, and the assumptions we have made with respect
to the data where they are not readily available from publicly available information. For example,
assumptions are made with respect to the age distribution of pensioners and the average pension by
age for current pensioners as at December 31, 2021 for the CPP and starting pensioners for a
potential APP.
Canada (without Québec) population and wages

We have used Statistics Canada’s projected population information for Canada (without Québec)
(from Statistics Canada’s estimate from the 2016 census) to reproduce the results from the CPP 31
Report. The chart below shows the distribution of the projected 2021 population by age group.
Chart C.2.1 – Distribution of Canada (without Québec) population as of 2021 (000s)

Age Female Male
Group
100+ 8 2
95 to 99 42 15
90 to 94 126 67
85 to 89 234 162
80 to 84 353 282
75 to 79 506 444
70 to 74 734 666
65 to 69 876 815
60 to 64 1,008 971
55 to 59 1,047 1,029
50 to 54 958 936
45 to 49 940 909
40 to 44 973 943
35 to 39 1,045 1,049
30 to 34 1,053 1,084
25 to 29 1,004 1,077
20 to 24 939 1,026
15 to 19 799 833
10 to 14 797 829
5 to 9 772 809
0 to 4 713 750
Total 14,927 14,697

In addition, we have used CPP31 Table 58 (Average Annual Earnings) for 2022 by age group in our
reproduction of the CPP 31 Report results. The following table provides a distribution of wages by
age.
Table C.2.1 – Average annual earnings by age group, 2022

Age Group Female Male
20 to 24 $23,168 $28,844
25 to 29 $39,661 $47,880
30 to 34 $45,928 $59,805
35 to 39 $50,383 $65,016
40 to 44 $54,550 $67,857
45 to 49 $55,927 $69,087
50 to 54 $55,028 $67,653
55 to 59 $50,474 $62,875
60 to 64 $41,524 $54,073
65 to 69 $28,459 $38,633
We compared the Statistics Canada summary information to those disclosed in the CPP 31 Report to
ensure that the information we used is consistent with those used for the CPP 31 Report.

Alberta population and wages
To prepare the calculations with respect to an APP, we have also utilized Alberta population and wage
information from Statistics Canada (consistent with the Canada without Québec information outlined
above). The summary of population and wages by age groups are provided below.
Chart C.2.2 – Distribution of Alberta population as of 2021 (000s)

Age Female Male
Group
100+ 1 1
95 to 99 4 2
90 to 94 14 8
85 to 89 26 18
80 to 84 40 32
75 to 79 58 51
70 to 74 86 80
65 to 69 112 109
60 to 64 135 134
55 to 59 139 139
50 to 54 132 137
45 to 49 144 148
40 to 44 163 165
35 to 39 180 184
30 to 34 172 179
25 to 29 147 157
20 to 24 132 142
15 to 19 126 131
10 to 14 137 143
5 to 9 137 142
0 to 4 127 132
Total 2,210 2,234
Table C.2.2 – Average annual earnings by age group for Alberta employees, 2017 to 2019
Age Group Female Male
16 to 24 $16,733 $22,867
25 to 34 $44,200 $68,167
35 to 44 $57,900 $87,667
45 to 54 $62,167 $97,200
55 to 64 $48,067 $79,733
65+ $23,433 $38,567
Average pensionable earnings for Alberta are determined using an assumed 30%/40%/30%
distribution of low/medium/high income earners and the same coefficient of variation that produced
a close fit with CPP average pensionable earnings provided in the CPP31 report.
Starting number of pensioners and starting pension amounts

Since information (number and distribution) relating to Alberta CPP pensioners is not publicly
available, we have extrapolated the starting pensioners and beneficiaries based on the summary data
provided in the CPP 31 Report and prorated the figures for Alberta based on the retirement eligible
population in Alberta compared to the Canada (less Québec) retirement eligible population.

We have assumed that all pensioners will have the same amount of pension as a percentage of
covered earnings and that Alberta pensioners will have starting pension amounts the same as that for
CPP pensioners.
C.3 – Methods in actuarial model

Our modelling projects future CPP and APP contributors, pensioners and finances through projecting
the general population, general economy, labour force, wages and pensions. The actuarial valuation
uses the following steps:
• Projection of Canada’s future demographic and economic environment.
• Projection factors are determined and used in combination with the demographic/economic
framework to estimate future cash flows and reserves.
The minimum contribution rate is then calculated such that the ratio of funds to expenditures remain
stable for the next 60 to 80 years. For the Base CPP and Base APP the test for asset-to-expenditure
ratios to be equal uses years 13 and 63 after the valuation date while for the Additional CPP and
Additional APP, the years used are 2088 and 2098.
The pay-as-you-go rate is the contribution rate applied to total contributory earnings to match the total
expenditure in a given year.
Total
Population
Pop Aged
Pop 0 to 14
15+
Active Pop Inactive
Employed
(A/CPP Unemployed
contributors)
Pensioners Pensioners
(if meet (if meet
criteria) criteria)
Projection of population
The projection of population begins with the population data as at July 1, 2021. From there,
assumptions on fertility, net migration, and mortality are applied to obtain the projected total active
population. The employed population is then determined using assumed labour force participation
rates and unemployment rates. Further, by applying assumptions on retirement, disability and death,
the model estimates the population eligible for benefits.

Projection of CPP and APP income and expenditure
The projection addresses all CPP and possible APP revenue and expenditure items. Projections of
pensions are performed following a year-by-year cohort methodology. For each year up to 2100, the
number of contributors and pensioners, and the dollar value of contributions, benefits and
administrative expenditure, is estimated.
Once the projections of the employed population, as described in the previous section, are complete,
contribution income is then determined from the proportion of contributors, projected total contributory
earnings, and the contribution rate.
Benefit expenses are payable amounts based on the CPP provisions as at December 31, 2021, and
the projected population eligible for benefits. Investment income is based on the assumed yield on
the beginning-of-year reserve and net cash flow in the year. The CPP’s administrative expenses are
modelled as a percentage of employment earnings. Finally, the end-of-year reserve is the beginning-
of-year reserve plus the net result of cash inflow and outflow.
Calculation of minimum contribution rates under an APP

For the purposes of determining the minimum required contribution rate for the Base APP, we have
combined the benefits under the Base CPP and calculated only one steady state contribution rate,
using the same methodology as the CPP 31 Report (i.e., so that the resulting asset-to-expenditure
ratios are the same in the 13th and the 63rd years following the valuation date).
The additional minimum required contributions under the CPP are defined specifically in the
Calculation of Contribution Rates Regulations, 2018 as the lowest level contribution rates, applicable
after the end of the review period, to the nearest 0.0001 percentage points, such that the following
conditions are met:
• the present value of projected additional open group obligations are at least equal to the projected
additional assets and present value of the projected additional contributions (open group assets);
• the projected asset/expenditures (A/E) ratio of the additional plan is the same in the 50th and 60th
years following the end of the review period, but no earlier than in the years 2088 and 2098,
respectively; and
• the Second Additional Minimum Contribution Rate equals the First Additional Minimum
Contribution Rate multiplied by the ratio of the earnings replacement rate of the second tier of the
additional plan to the replacement rate of the first tier (which equals 4).
For the purposes of determining the additional minimum required contributions under an APP in this
report, we have not performed the open group calculation described in the first condition above. We
do not believe that the open group calculation would have any impact of the resulting additional
minimum contribution rates determined. As such, we have also not replicated the open group
calculations for the CPP disclosed in the CPP 31 Report.
C.4 – Assumptions
The main actuarial assumptions used are summarized in the following table. The results provided in
this report are based mainly on the assumptions used in the CPP 31 Report. Adjustments to any
assumptions and methodology as a result of incomplete data in the CPP 31 Report are summarized
in the following sections. All rates and percentages are annualized unless otherwise noted.

Table C.4.1 – Summary of assumptions
CPP 31 Report Adaptation for APP
Fertility
- initial rate Per CPP 31 Report See Table C.4.3
- ultimate rate 1.54 (2029+) Same
Sex ratio of newborns 1.053 Same
Migration Ultimate 0.64% + 0.04% of population with Same percent as for CPP but
age/sex distribution from Statistics Canada Alberta age distribution from
Statistics Canada migration
estimates for 2015/16 to 2019/20
Mortality – population (CLT 1-year table: 2019 Tables) with Same

improvements as per Table 41 in the CPP
31 Report
Up to age 60 – population
Mortality – pensioners Same
60+ - CPP
Mortality – disabled pensioners See Table 93 of CPP 31 Report Used 10 times population
mortality
Labour force, participation, See Table 50 of the CPP 31 Report Same

employment and unemployment
rates
CPP contributors (% of employed See Table 62 of CPP 31 Report Same

population)
Real wage increase -2.4% in 2022, 0.3% in 2023 increasing to Same

0.9% in 2026+
Inflation 6.9% in 2022, 3.0% in 2023, 2.5% in 2024, Same

2.3% in 2025 and 2.0% all years thereafter
% of contributors married See Table 94 of CPP 31 Report Same
Disability incidence See Table 90 of CPP 31 Report Same

(per 1,000 eligible)
Avg. number of children Estimated Same
Death benefit % of children benefit Same
Retirement pension take-up rates See Table 81 of CPP 31 Report Same
Operating expenses Rate that produces 1st year actual. (CPP Same percentage of covered
report uses total earnings as a base) wages as CPP
Real rate of return See Table 72 of CPP 31 Report Same

(average 2022-2100)
Mortality rates and life expectancies

The model uses the same Statistics Canada Life Tables (CLT 1-year average table: 2019 Tables)
with future mortality improvement as the CPP 31 Report. The future mortality improvements rates
from the CPP 31 Report were interpolated to obtain specific age-related mortality improvement rates
to be used for our model.

Table C.4.2 – Life expectancy under mortality assumptions
Canadian Life Expectancy Males Females
at birth in 2022 86.7 years 90.0 years
at age 65 in 2022 21.3 years 23.8 years
Age-specific and total fertility rates

The model uses the fertility rates provided in CPP 31 Report and fitted a fertility curve to obtain age
specific fertility rates. Sample fertility rates are provided in Table C.4.3.
Table C.4.3 – Age-specific and total fertility rates (TFR) – replication of CPP 31 Report
2022 2023 2024 2025 2026 2027 2028 2029
15-19 0.0057 0.0055 0.0053 0.0052 0.0050 0.0048 0.0047 0.0045
20-24 0.0285 0.0274 0.0263 0.0253 0.0242 0.0231 0.0220 0.0209
25-29 0.0787 0.0780 0.0774 0.0768 0.0762 0.0756 0.0750 0.0745
30-34 0.1080 0.1095 0.1109 0.1124 0.1139 0.1154 0.1168 0.1183
35-39 0.0610 0.0628 0.0645 0.0663 0.0680 0.0697 0.0714 0.0732
40-44 0.0136 0.0140 0.0144 0.0148 0.0152 0.0156 0.0161 0.0165
45-49 0.0009 0.0009 0.0009 0.0009 0.0009 0.0010 0.0010 0.0010
TFR 1.48 1.49 1.50 1.51 1.52 1.53 1.54 1.54
Retirement rates
The model uses the retirement rates provided in CPP 31 Report.
Assumptions used for the Higher Growth and Lower Growth

projection scenarios
Alberta currently accounts for about 11.6% of the population in Canada. Using the assumptions
outlined in the CPP 31 Report, Alberta’s population will grow to around 13.3% of Canada in 2100.
Based on a review of the components of historical Alberta population growth compared to that of
Canada, we believe that the assumptions in the CPP 31 Report represent a reasonable expectation
of how Alberta’s population might grow in the future, and therefore will produce a reasonable long
term projection of Alberta’s size compared to Canada. In order to illustrate how the cost of an APP
may change if Alberta’s growth is higher or lower than that assumed, we have also calculated the
required contributions under an APP with a higher growth and a lower growth scenario. Under the
higher growth scenario, Alberta will maintain a higher rate of growth (comparable to the recent average
rate) relative to Canada throughout the projection period, with an ultimate population at around 19%
of the total Canadian population. Under the lower growth scenario, Alberta’s population will become
a smaller proportion of Canada’s population – roughly 10% of the Canadian population.

Chart C.4.1 – Historical Alberta population and projection of Alberta population
Size of Alberta population relative to total Canadian population

25%
20%
Higher Growth Scenario
15%
Best Estimate Scenario
10%
Lower Growth Scenario
5%
0%
1961 1971 1981 1991 2001 2011 2021 2031 2041 2051 2061 2071 2081 2091
The table below shows the underlying assumptions under the higher and lower growth scenarios we
have used to determine the contribution requirements under an APP.
Table C.4.3 – Comparison of the assumptions used in the Higher Growth and Lower Growth
population / economic projection scenarios
Scenario Best Estimate Lower Growth Higher Growth
Relative size in 2050 12.6% 12.1% 13.9%

Relative size in 2100 13.3% 10.6% 18.8%
Fertility 1.49 to 1.54 (2027) 1.65 to 1.55 (2027) 1.66 to 1.71 (2031)
Migration 1.23% in 2022 1.30% in 2022 1.6% in 1.30% in 2022 1.6% in
decreasing to 0.68% in 2023, decreasing to 2023, decreasing to
2031, remaining constant 0.45% in 2031, remaining 0.90% in 2031, remaining
thereafter constant thereafter constant thereafter
Economic growth 1.70% 1.40% 2.00%
Real wage growth 0.90% 0.70% 1.10%
Inflation 2.00% 2.00% 2.00%
Investment returns (Base APP) 6.02% 6.02% 6.02%
The values for all other assumptions are similar across scenarios.

Assumptions for sensitivity analysis
We have used the same sensitivity assumptions as those used in the CPP 31 Report.
Table C.4.4 – Individual sensitivity test assumptions

Assumption Lower Cost Best Estimate Higher Cost
1. Total Fertility Rate 1.84 1.54 1.24
2. Mortality: Males: 25.2
Males: 20.9 Males: 23.1
Canadian Life Expectancy at age 65 in 2050 with future Females:
Females: 23.3 Females: 25.4
improvements 27.4
3. Net Migration Rate 0.88% 0.68% 0.48%
4. Price Increases 3.0% 2.0% 1.0%
5. Real Wage Increases – Base APP 1.5% 0.9% 0.3%
Real Wage Increases – Additional APP 0.3% 1.0% 1.5%
6. Real Rate of Return on Investments – Base APP 5.29% 3.69% 2.09%
Real Rate of Return on Investments – Additional APP 4.47% 3.72% 2.07%
Assumptions for Adverse Scenarios Analysis
Table C.4.5 – Wage increase assumption used in change in earners and earnings distribution adverse
scenario
Average Wage of Earners in Group Best Estimate Alternate Scenario
Low – 45% of average earnings 2.9% 1.5%
Medium – 85% of average earnings 2.9% 2.6%
High – 167% of average earnings 2.9% 3.5%
Note: These changes are up to 2045 only. The proportion of earners assumed in the low, medium and high-
income groups are 30%, 40% and 30%, respectively.
Table C.4.6 – Assumptions used in stagflation adverse scenario

Year Inflation Rate Unemployment Rate Nominal Wage Increase
Best Stagflation Best Stagflation Best Stagflation*
Estimate Estimate Estimate
2022 6.9% 6.9% 6.0% 6.0% 3.1% 3.1%
2023 3.0% 10.0% 5.7% 5.7% 2.9% 6.4%
2024 2.5% 10.0% 5.8% 8.0% 2.9% 6.7%
2025 2.3% 9.0% 5.9% 9.0% 2.9% 6.3%
2026 2.0% 8.0% 6.0% 10.0% 2.9% 6.5%
2027 2.0% 7.0% 6.1% 9.5% 2.9% 6.4%
2028 2.0% 6.0% 6.1% 9.0% 2.9% 6.1%
2029 2.0% 5.0% 6.1% 8.5% 2.9% 5.6%
2030 2.0% 4.0% 6.1% 8.1% 2.9% 4.9%
2031 2.0% 3.0% 6.1% 7.6% 2.9% 3.9%
2032 2.0% 2.0% 6.1% 7.1% 2.9% 2.9%
2033 2.0% 2.0% 6.1% 6.6% 2.9% 2.9%
2034 2.0% 2.0% 6.1% 6.1% 2.9% 2.9%
* Assumes only 50% of the additional inflation is added to nominal wage increase rate
No change in asset returns is assumed.

Table C.4.7 – Assumptions used in Transition to Green Economy adverse scenarios
Scenario Cumulative Effect on Nominal GDP Asset Returns
(starting 2020)
2030 2050 2100
1 -5% -10% -10% -0.09%
2 0 -15% -20% -0.17%
3 0 -8% -30% -0.31%
Note: Lower nominal GDP totals achieved by lower real wage growth (no change in employment).
C.5 – Detailed CPP provisions for modelling

The following is a summary of the main plan provisions currently in effect for the CPP. These
provisions are based upon the CPP Act and the regulations made thereunder (the CPP Regulations),
as well as information from historical CPP annual reports and actuarial reports. A summary of the key
plan provision differences found in the QPP is shown at the end of this section.
Definitions
Additional CPP: The additional CPP refers to the enhancement to the CPP introduced in An Act to
Amend the Canada Pension Plan, the CPPIB Act and the Federal ITA. The additional CPP was
implemented as of January 1, 2019. The additional CPP has two (first and second) parts, and the
corresponding first and second additional contribution rates and pensionable earnings on which
contributions are made are being phased in over a seven-year period from 2019 to 2025.
Base CPP: The Base CPP refers to that part of the CPP other than the part relating to the additional
CPP. Prior to January 1, 2019, the CPP consisted only of the Base CPP.
Contributory Period: The contributory period is in respect of the Base CPP and is the number of
months from attainment of age 18 (or from January 1, 1966, if later) to the earliest of:
i. the month in which the contributor dies,
ii. the month before the one in which the retirement pension commences, and
iii. the month before the one in which the contributor reaches 70 years of age,
less the number of months during which the contributor received a CPP or QPP disability benefit
(including the three-month waiting period), or during which the contributor had at least one eligible
child under seven years of age and had earnings for that year lower than the YBE. The contributory
period excludes periods on or after January 1, 2012 during which beneficiaries contribute while in
receipt of a retirement pension.
First additional contributory period: The first additional contributory period is in respect of the
additional CPP and is the number of months from attainment of age 18 (or from January 1 2019, if
later) to the earliest of:
ii. the month before the one in which the retirement pension commences and
iii. the month before the one in which the contributor reaches 70 years of age.
Second additional contributory period: The second additional contributory period is in respect of
the additional CPP and is the number of months from attainment of age 18 (or from January 1, 2024,
if later) to the earliest of:
ii. the month before the one in which the retirement pension commences and
iii. the month before the one in which the contributor reaches 70 years of age.

Year’s Basic Exemption (YBE): The YBE for a calendar year is the minimum employment earnings
required to participate in the CPP. As well, contributions are waived on earnings up to the YBE. The
YBE has been frozen at $3,500 per year since 1996.
Year’s Maximum Pensionable Earnings (YMPE): The YMPE for a calendar year is the limit to which
employment and self-employment earnings are subject to contributions and first additional
contributions for purposes of the Base CPP and Additional CPP, respectively. The YMPE increases
each year based on average weekly earnings increases measured using publications from Statistics
Canada.
Year’s Additional Maximum Pensionable Earnings (YAMPE): The YAMPE for a calendar year is
the limit to which employment and self-employment earnings are subject to second additional
contributions above the YMPE for the purposes of the Additional Plan. The YAMPE will be introduced
in the year 2024. The YAMPE will first be set at 107% of the YMPE in 2024, and then at 114% of the
YMPE in 2025 and thereafter. The YAMPE is thus set to increase in tandem with the YMPE after
2025.
Eligibility
Retirement benefits
• Any person who has attained age 60 and made at least one contribution to the CPP or has
received at least one valid contribution from credit splitting is eligible to receive retirement benefits
from the plan. This includes both the Base CPP retirement benefit and the Additional CPP
retirement benefit.
Post-retirement benefits
• Since 2012, individuals under the age of 65 who receive a CPP retirement pension and continue
to work in Canada outside of Québec are required, along with their employers, to contribute to the
CPP. Working beneficiaries aged 65 to 69 are not required to contribute, but are given the option
to do so. No contributions are made after age 70. Employers of those working beneficiaries opting
to contribute are also required to contribute.
• Working beneficiaries are eligible to receive a post-retirement benefit, payable from the CPP the
year following the year in which the applicable contributions are made.
• Contributions toward a post‑retirement benefit do not increase the amount of other CPP benefits
and they do not determine eligibility for CPP benefits, other than the post‑retirement disability
benefit.
Disability benefits
• A person is considered disabled if the person is suffering from a severe and prolonged mental or
physical disability. A disability is considered severe if by reason of it the person is regularly
incapable of pursuing any substantially gainful occupation; a disability is considered prolonged if
it is likely to be long-continuing and of indefinite duration or likely to result in death.
• A person who becomes disabled prior to age 65 and is not receiving a CPP retirement pension is
eligible for a disability pension provided that contributions have been made, at the time of
disablement, for at least four of the previous six calendar years, counting years included wholly or
partly in the contributory period. Contributions must be on earnings that are not less than 10% of
the YMPE rounded, if necessary, to the next lower multiple of $100. Since 2008, contributors with
25 or more years of contributions to the CPP can meet the eligibility requirement with contributions
in three of the last six years. These eligibility requirements include both the Base CPP disability
benefit and the additional CPP disability benefit.

Post-retirement disability benefit
• Beginning in 2019, a flat-rate post-retirement disability benefit is payable under the Base CPP to
retirement beneficiaries who are deemed disabled while under age 65.
• The post-retirement disability benefit pertains only to the Base CPP benefit. There is no additional
post-retirement disability benefit payable under the Additional CPP benefits.
Survivor benefits
A legal spouse, a separated legal spouse not cohabiting with a common-law partner, or a common-
law partner of a deceased contributor, is eligible for a survivor’s benefit if the following conditions are
met as at the date of the contributor’s death:
• The deceased contributor must have made contributions during the lesser of ten calendar years,
or one-third of the number of years included wholly or partly in their contributory period, but not
for less than three years.
• If the surviving spouse is the separated legal spouse of the deceased contributor, there must be
no cohabiting common-law partner of the contributor at the time of death. If the survivor is the
common-law partner of the deceased contributor, the couple must have cohabited for not less
than one year immediately before the death of the contributor. If the common-law partner is of the
same sex as the deceased contributor, the death must have occurred on or after April 17, 1985.
• Prior to 2019, the surviving spouse or common-law partner must have had dependent children,
been disabled, or been at least 35 years of age. As of January 1, 2019, these conditions no longer
apply.
Contributions
Both the base and additional CPP benefits are financed through mandatory contributions from
employees, employers and those who are self‑employed, and through the revenue earned on CPP
investments.
Workers start contributing to CPP at age 18. Contributions at the base contribution rate and first
additional contribution rate are made on earnings between the YBE and the YMPE. Contributions at
the second additional contribution rate are made on earnings between the YMPE and YAMPE. The
contribution rates for employers are the same as those for workers.
In respect of the Base CPP, from 1966 to 1986, the annual contribution rate applicable to contributory
earnings was 1.8% for employees (and the same amount for their employers) and 3.6% in respect of
self-employed earnings. Following 1986, rates increased steadily to their current levels shown in the
table below. The rates in the table below are for the worker and employer combined. A self-employed
member would contribute this entire amount themselves.
Table C.5.1 – Legislated contribution rates under the CPP

Pensionable Earnings above Pensionable Earnings above YMPE
YBE up to YMPE up to YAMPE
Year Base Contribution Rate First Additional Contribution Rate Second Additional Contribution Rate
2003-2018 9.9% - -
2019 9.9% 0.3% -
2020 9.9% 0.6% -
2021 9.9% 1.0% -
2022 9.9% 1.5% -
2023 9.9% 2.0% -
2024+ 9.9% 2.0% 8.0%*
* In 2024, the YAMPE will be 7% higher than the YMPE as a transition. In 2025 and beyond it is 14% higher
than the YMPE.

Retirement dates
Eligible participants may elect to commence their retirement pension at any time after attaining age
60.
Pension amounts shall be reduced at a rate of 0.6% for each month that the commencement date
precedes the participants’ 65th birthday.
Pension amounts shall be increased at a rate of 0.7% for each month commencement is postponed
past the participants’ 65th birthday, up to the earlier of the commencement date and the participants’
70th birthday.
Calculation of benefits
1) Retirement benefits: Base CPP
The initial monthly retirement pension payable under the Base CPP at age 65 is based on the
contributor’s entire history of pensionable earnings during the contributory period. The
retirement pension under the Base CPP is equal to 25% of the average of the YMPE for the year
of retirement and the four previous years, referred to as the Maximum Pensionable Earnings
Average (MPEA), adjusted to take into account the contributor’s pensionable earnings. For this
purpose, the contributor’s pensionable earnings for any given month are indexed by the ratio of
the MPEA for the year of retirement to the YMPE for the year to which the given month belongs.
Drop-out provisions allow certain periods with low pensionable earnings to be excluded from the
base CPP pension calculation:
• General drop-out provision – CPP participants are able to drop up to 17% of their lowest
months of earnings (maximum 8 years) from the calculation of their retirement benefit.
• Child rearing drop-out provision – Participants can drop periods of low earnings related
to child-rearing for a child less than seven years of age. This is done prior to the general
dropout of 17% mentioned above.
• Disability drop-out provision – Any period that a member is receiving a disability pension
will not count towards their contributory period. Additionally, if the member was on disability
up to age 65 then their pensionable earnings are adjusted based on the YMPE when the
member first went on disability and then accumulated according to CPI from that time to age
65.
• Should the member retire between age 65 and age 70, there is an additional drop-out
provision:
o If a member is still working after age 65, those earnings can be used to replace any
earnings from before age 65 that were lower.
o If the earnings after age 65 are less than any adjusted pensionable earnings in years
prior to turning age 65, they can simply be dropped (will not count towards the
general drop-out provision).

2) Retirement benefits: Additional CPP
The calculation of the additional CPP retirement benefit is based on the first and second
additional monthly pensionable earnings. The first additional monthly pensionable earnings are
equal to the total of the highest 480 months or the total number of months, if lower, in the first
additional contributory period of monthly adjusted pensionable earnings up to the YMPE divided
by 480. Similarly, the second additional monthly pensionable earnings are equal to the total of
the highest 480 or total number of months, if lower, in the second additional contributory period
of monthly adjusted pensionable earnings between the YMPE and the YAMPE divided by 480.
These calculations provide for a monthly accrual of 1/480 of the total additional retirement
benefit.
The additional monthly retirement benefit is calculated as the sum of 8.33% of the first additional
monthly pensionable earnings and 33.33% of the second additional monthly pensionable
earnings.
The pensionable earnings used for the calculation of additional retirement benefits are adjusted
to the date of retirement in the same way as for the base CPP, that is, indexing by the ratio of
the MPEA to the YMPE as described above. Further, to account for the lower first additional
contribution rates during the first four years of the phase-in period (from 2019 to 2022), the first
additional monthly pensionable earnings are multiplied by 0.15 in 2019, 0.30 in 2020, 0.50 in
2021, and 0.75 in 2022.
There are no drop-out periods as in the Base CPP portion. However, drop-in provisions do exist
for members with periods of low earnings resulting from disability or child-rearing for a child of
less than seven years of age.
• Disability drop-in provision – If a member becomes disabled after January 1, 2019 an

imputed income will be assigned to those disability periods of low or zero earnings for the
purpose of calculating the Additional CPP retirement (and survivor) benefits. The drop-in
amount will be equal to 70 per cent of an individual’s average earnings in the six years prior
to the onset of the disability. If fewer than six years of earnings exist between January 1,
2019 and the date of disability, then the drop-in will be calculated based on the actual number
of earnings months after 2018, prior to the onset of disability.
• Child rearing drop-in provision – For parents of children under the age of seven on or
after January 1, 2019, an imputed income will be assigned to child-rearing periods of low or
zero earnings on or after January 1, 2019 for the purpose of calculating Additional CPP
benefits. The drop-in amount is equal to the parent’s average earnings during the five years
prior to the birth or adoption of the child if that amount is higher than their actual earnings
during the period the child was younger than age seven.
• The child-rearing drop-in amount is calculated based on months of earnings after 2018 and
prior to birth or adoption of a child. If, however, there are fewer than 60 such months (5
years), then the drop-in is calculated based on the actual number of earnings months, but
not lower than 36. If there are less than 36 such months of earnings, the drop-in will be
calculated using imputed earnings of 40% of the YMPE for the number of months missing
from the minimum of 36.
3) Post-retirement benefits
The post‑retirement benefit allows CPP retirement pension beneficiaries who keep working to
increase their retirement income by continuing to contribute to the CPP, even if they are already
receiving the maximum CPP retirement pension.

The post-retirement benefit is earned at a rate of 1/40 of the maximum retirement pension per
year of post-retirement contributions and is adjusted for the applicable earnings level and age
of the contributor.
A post-retirement benefit becomes payable the year following the year in which contributions
are made, and multiple post-retirement benefits may accumulate over time. The total pension
payable resulting from the combination of the retirement pension and post-retirement benefit
may be greater than the maximum CPP or QPP pension payable. As for the CPP retirement
pension, the post-retirement benefit is payable for a beneficiary’s lifetime.
4) Disability benefits
The initial Base CPP monthly disability benefit is the sum of a flat-rate portion payable depending
only on the year in which the benefit is payable and an earnings-related portion equal to 75% of
the Base CPP retirement pension that would be payable at the onset of disability if the
contributory period ended on that date and no actuarial adjustment applied.
The initial amount of the Additional CPP monthly disability benefit is strictly earnings-related and
is equal to 75% of the additional retirement pension that would be payable at the onset of
disability if the first and second additional contributory periods ended on that date and no
actuarial adjustment applied.
The automatic conversion of the CPP disability benefit into a retirement pension at age 65 is
determined by base and additional pensionable earnings at the time of disablement, price-
indexed to age 65.
The post‑retirement disability benefit, introduced in 2019, is a monthly flat‑rate that is provided
in addition to the individual’s retirement pension. The value of the post‑retirement disability
benefit is equal to the flat‑rate component of the disability pension and is payable under the base
CPP to retirement beneficiaries who are deemed disabled while under age 65. The post-
retirement disability benefit pertains only to the Base CPP. There is no additional post-retirement
disability benefit payable under the Additional CPP.
A flat-rate benefit is also payable to dependent children of disabled beneficiaries. To be eligible,

children must be under 18 years of age or under 25 and in full‑time attendance at school or
university.
5) Survivor benefits
The amount of survivor pension depends on whether the survivor is over or under age 65 and
whether or not they also receive other CPP benefits.
• New survivor under age 65 – The benefit is the sum of the flat rate and earnings-based
components:
o The Base CPP flat-rate survivor’s benefit depends only on the year in which the
survivor’s benefit is payable.
o The earnings-related benefits payable under the Base and Additional CPP depend
initially only on the contributor’s record of pensionable and additional pensionable
earnings, respectively as at the date of death. The initial earnings-related survivor’s
benefit is equal to 37.5% of either the retirement pension of the deceased contributor
if they had been receiving a pension, or the retirement pension that would have been
payable to the deceased contributor if the contributory and additional contributory
periods had ended at the time of death, with no actuarial adjustment in either case.

• New survivor over age 65 – At age 65, or upon becoming widowed at a later age, an eligible
surviving spouse or common-law partner is entitled to a monthly survivor’s benefit equal to
60% of either the retirement pension of the deceased contributor if they had been receiving
a pension, or the retirement pension that would have been payable to the deceased
contributor if the contributory and additional contributory periods had ended at the time of
death, with no actuarial adjustment in either case. However, the total benefit an individual
surviving spouse or common-law partner may receive, including their own pension, cannot
exceed the maximum CPP pension payable.
6) Death benefit
A lump sum benefit is payable to the estate of a deceased contributor if the eligibility rules for
the survivor’s benefit are met. Prior to 2019, the amount of the death benefit was equal to six
times the monthly amount of the CPP retirement pension accrued or payable in the year of
death, adjusted to exclude any actuarial adjustments, and subject to a maximum of ten percent
of the YMPE for the year of death prior to 1998, and $2,500 thereafter. As of January 1, 2019,
the death benefit equals the flat-rate amount of $2,500.
The death benefit pertains only to the Base CPP. There is no Additional CPP death benefit.
7) Child’s benefits
Each child under age 18 and each full-time student aged 18 to 25 who is dependent on a
contributor eligible for a CPP disability benefit (the disability pension or post-retirement disability
benefit) or who was dependent on a deceased contributor who satisfied the requirements for a
survivor’s pension is entitled to a flat-rate monthly benefit. An eligible child may not receive
child’s benefits in respect of more than two contributors.
The child’s benefits pertain only to the Base CPP. There are no Additional CPP child’s benefits.
Inflation adjustments
All monthly CPP benefits are indexed annually in accordance with inflation. Benefit amounts are
adjusted in January of each year to reflect increases in the Consumer Price Index published by
Statistics Canada. The prescribed increase each year is calculated as the average for the 12-month
period ending October 31st in the preceding year of the Consumer Price Index for each month in that
12-month period (minimum 0%).
Credit splitting
Pensionable and additional pensionable earnings may be split between separated or divorced couples
(married spouses or common-law partners) for each month the couple lived together. Pensionable
earnings (of the Base CPP) are used to establish eligibility for CPP benefits, and both pensionable
and additional pensionable earnings are used to calculate the amounts of benefits.
Contributors may obtain a credit split even if they have remarried. However, pensionable and
additional pensionable earnings cannot be split for any year in which the total earnings of the former
couple do not exceed twice the YBE. Credit splitting also does not apply for any period of cohabitation
during which a former spouse or common-law partner received a CPP retirement pension.

Pension sharing
Couples (legal spouses or common-law partners) in an ongoing relationship may voluntarily (at the
request of one of them) share their CPP retirement pensions corresponding to the number of years
during which they cohabited. This applies provided both spouses have reached the minimum age
requirement to receive a retirement pension. Sharing is possible even if only one of the spouses has
participated in the CPP. Pension sharing ceases upon separation, divorce, or death.
QPP key provisions

The provisions for the QPP are in general aligned with those of the CPP. Some of the key QPP
provisions are described below, including those that differ significantly from the CPP.
Changes to some QPP provisions were announced in 2023 (to become effective as of January 1,
2024) and are not reflected in the sections below. These changes relate to how benefits are calculated
for workers over age 65 and also extend the maximum retirement age under QPP from 70 to 72.
Note that the additional component of QPP, affecting participants from January 1, 2019 onward,
provides for contributions and pension benefits that are identical to that of the additional component
of CPP.
Participation
Subject to certain exceptions, any person at least 18 years of age who receives earnings from work
performed in Québec must contribute to QPP if their annual income is greater than the general
exemption, unless they receive the disability pension under QPP or an equivalent plan. Recipients of
a retirement pension who are working are also required to contribute.
Contributions
The QPP contribution structure is the same as that of CPP. For the base QPP plan, contributions are
made on eligible income between the annual exempt amount of $3,500 and the Maximum
Pensionable Earnings (MPE) level for the year. The MPE applicable to QPP contributions is identical
to the YMPE each year. Similar to CPP, QPP contributions are divided evenly between workers and
employers.
From 1966 to 2011, contribution rates for base QPP were identical to that of base CPP. Beginning in 2012
and up to and including 2017, base QPP contribution rates diverged from the CPP rate of 9.9% as seen
in the table below:
Table C.5.2 – Legislated contribution rates for the Base benefit under QPP
Time Period QPP Employee QPP Employer QPP Self-employed
Contribution Contribution Rate Contribution Rate
Rate
2011 4.95% 4.95% 9.90%
2012 5.03% 5.03% 10.05%
2013 5.10% 5.10% 10.20%
2014 5.18% 5.18% 10.35%
2015 5.25% 5.25% 10.50%
2016 5.33% 5.33% 10.65%
2017 onward 5.40% 5.40% 10.80%

The contributory service period for a participant in the base QPP begins on the first day of the month
following their 18th birthday (or January 1st, 1966, if later) and ends at the first of the following months:
• the month preceding the start of payment of the retirement pension;
• the month of 70th birthday of the person;
• the month of the person's death.
Automatic adjustment mechanism

Base QPP
The steady-state contribution rate allows the application of the automatic adjustment mechanism
required under section 44.1 of the Act Respecting the Québec Pension Plan (the QPP Act). This
mechanism restores the stability of the funding of the basic plan, if necessary. When the steady-state
contribution rate exceeds the basic contribution rate provided for by law by at least 0.1%, the latter is
increased at the rate of 0.1% annually, until the difference between the two rates becomes less than
0.1%. The government can decide to suspend this automatic adjustment by decree.
Supplementary Plan
The QPP Act provides for an automatic adjustment mechanism which will allow the funding of the
supplementary plan to be re-established, if necessary. The details of this mechanism have not been
defined at this time.
Dropout periods
Under the base QPP, dropout periods differ from those under the base CPP. For the base QPP, the
following periods are excluded from the contributory period:
• up to 15% of months of low or no earnings;
• the first three months preceding the start of payment of a disability pension (if the date of disability
is after June 30, 1993) and the months during which the person received this pension under the
QPP;
• the months for which family benefits have been paid for a child under the age of seven, if these
months are part of a year in which the income from work was lower than the general exemption;
• certain months for which an unreduced income replacement insurance is paid under the Act
Respecting Industrial Accidents and Occupational Diseases.
Retirement pension commencement

In order to be eligible for a QPP retirement pension, a person must have contributed to the plan and
attained age 60. The person can receive their retirement pension while continuing to work. Working
beneficiaries are required to continue contributing to the plan in most cases, and are eligible for a
supplementary benefit similar to the post-retirement benefit under the CPP.
A person who applies for their retirement pension after the age of 65 is entitled to receive a retroactive
retirement pension. The retroactive period can reach a maximum of 12 months and cannot include
months included in the period preceding the individual’s 65th birthday.
The calculation of the initial QPP retirement pension amount is the same as that of the CPP for both
the base and additional parts of the plan.
The adjustment factors for early retirement (before 65) and postponed retirement (after 65) are the
generally the same as those under the CPP. The only exception is that an early retirement adjustment
factor of 0.5% per month may apply instead of the standard 0.6% per month in cases where the QPP
pension amount is very low.

QPP disability benefit
A person is considered disabled for the purposes of the QPP if they are suffering from a severe and
prolonged physical or mental disability. Disability is serious if it renders the person incapable of
regularly carrying out any meaningful gainful occupation. In this case, the disability is said to be total.
In addition, for a person aged 60 to 65, the disability is severe if their limitations make them unable
to carry out their usual paid occupation when they stop working because of their disability. In the
latter situation, the disability is said to be flexible.
The disability is prolonged if it is to result in death or, in all likelihood, to last indefinitely.
A person suffering from total disability may be entitled to a disability pension if they have contributed
to the plan:
• during two of the last three years of their contributory period;
• during five of the last ten years of their contributory period; or
• for at least half of their contributory period, but for at least two years.
A person aged 60 to 65 with flexible disability may be entitled to a disability pension if they have
contributed to the QPP during at least four of the last six years of their contributory period.
A person receiving a retirement pension aged 60 to 65 and suffering from total disability after the
first six months of payment of their retirement pension may receive the additional amount for
disability in the basic plan. To be eligible, they must have contributed to the plan for at least four of
the last six years.
The disability pension is not paid to persons who become beneficiaries of an unreduced income
replacement indemnity under the Act Respecting Industrial Accidents and Occupational Diseases.
The amount of the QPP disability benefit is comprised of a flat benefit provision as well as a variable
benefit provision. The calculation of each of these amounts is the same as under the CPP.
QPP survivor pension

To be eligible for a surviving spouse's pension, a death benefit or an orphan's pension, the deceased
must have paid contributions during one third of their contributory period, and for at least three years.
The required number of years of contribution is capped at ten, regardless of the number of years in
the contributory period.
Survivor benefit amounts are calculated dependent on the age of the surviving spouse as well as
whether they have a dependent child. The survivor benefit is composed of a flat portion as well as a
variable portion, similar to the CPP, but the different age categories mean the benefit amounts may
differ under the QPP in some scenarios.
The QPP orphan’s pension is a monthly amount paid to the individual who supports a minor child of
the deceased if the deceased contributed enough to the QPP. The orphan’s pension is a fixed monthly
amount for each child that is adjusted annually for inflation and is the same as under the CPP. It is
paid until the child turns 18.
Participation in both QPP and CPP

An administrative agreement between the QPP and the CPP exists and is used to determine the source
of benefit payments for beneficiaries who have contributed to both plans. The plans compensate each
other according to the participation of the beneficiaries in each of the plans, since only one plan pays
the benefit to each beneficiary. The paying plan is determined on the basis of the person's place of
residence when requesting the benefit.

C.6 – Replication of CPP 31 Report results
Comparison of LifeWorks (LW) model and CPP 31 Report
The minimum contribution rates obtained through our model for the Base CPP benefit, the First
Additional benefit and the Second Additional benefit are 9.57%, 1.98% and 7.92% respectively. These
rates are slightly higher than the minimum contribution rates disclosed in the CPP 31 Report at 9.54%
for the Base CPP, 1.97% for the First Additional benefit, and 7.88% for the Second Additional benefit.
Comparisons of projections in population, contributions, and benefits are shown in the tables below.
Differences are primarily attributed to additional assumptions needed in our model, due to the Chief
Actuary having additional information that is not publicly disclosed.
Table C.6.1 – Comparison of pay-as-you-go rates

Year CPP 31 Report LifeWorks Model
2022 9.08% 9.05%
2025 9.76% 9.81%
2030 10.35% 10.33%
2035 10.58% 10.60%
2040 10.72% 10.72%
2045 10.82% 10.83%
2050 11.05% 11.07%
2055 11.48% 11.45%
2060 12.06% 12.01%
2065 12.60% 12.60%
2070 12.91% 12.91%
2080 13.07% 13.06%
2090 13.04% 13.05%
2100 13.29% 13.25%
Table C.6.2 – Comparison of projected contributions ($ millions)

Base CPP Additional CPP
Year CPP 31 Report LifeWorks Model CPP 31 Report LifeWorks Model
2022 61,050 61,140 9,250 9,264
2025 70,338 70,306 18,174 18,185
2030 85,591 85,564 22,097 22,094
2035 103,693 103,606 26,690 26,699
2040 124,174 124,200 31,927 31,931
2045 148,443 148,513 38,103 38,183
2050 176,687 177,094 45,300 45,374
2055 208,701 208,893 53,476 53,504
2060 244,991 244,986 62,715 62,720
2065 287,400 287,177 73,523 73,469
2070 338,777 339,124 86,582 86,650
2080 475,589 476,258 121,412 121,550
2090 667,715 667,735 170,294 170,289
2100 928,529 928,718 236,708 236,757
Table C.6.3 – Comparison of projected expenditures ($ millions)

2022 56,005 55,889 287 302
2025 69,330 69,657 640 583
2030 89,472 89,303 1,982 1,979
2035 110,853 110,920 4,792 4,787
2040 134,439 134,525 9,598 9,595
2045 162,197 162,404 17,303 17,187
2050 197,151 198,053 29,370 29,153
2055 241,987 241,672 47,261 46,588
2060 298,489 297,239 71,950 71,598
2065 365,685 365,463 102,158 103,037
2070 441,724 442,066 135,530 136,129
2080 628,102 628,321 213,446 212,560
2090 879,465 879,866 311,022 310,743
2100 1,246,767 1,242,869 445,964 446,402

Table C.6.4 – Comparison of projected number of pensioners
2022 7,964 8,167 989 1,040
2025 8,705 8,822 1,998 2,269
2030 9,888 9,941 3,794 4,324
2035 10,793 10,805 5,716 6,217
2040 11,519 11,469 7,603 8,075
2045 12,176 12,154 9,403 9,825
2050 12,869 12,906 11,073 11,477
2055 13,629 13,642 12,529 12,997
2060 14,449 14,431 13,760 14,250
2065 15,222 15,218 14,733 15,109
2070 15,885 15,873 15,469 15,785
2080 17,020 16,994 16,620 16,772
2090 17,899 17,928 17,494 17,491
2100 18,916 18,935 18,503 18,310
Table C.6.5 – Comparison of projected number of contributors

2022 15,235 15,284 15,235 15,284
2025 15,959 15,597 15,959 15,597
2030 16,708 16,693 16,708 16,693
2035 17,464 17,460 17,464 17,460
2040 18,057 18,069 18,057 18,069
2045 18,686 18,699 18,686 18,699
2050 19,263 19,270 19,263 19,270
2055 19,687 19,681 19,687 19,681
2060 19,992 19,981 19,992 19,981
2065 20,289 20,278 20,289 20,278
2070 20,699 20,735 20,699 20,735
2080 21,805 21,850 21,805 21,850
2090 22,975 22,975 22,975 22,975
2100 23,973 23,965 23,973 23,965

Appendix D: Additional legal and
governance considerations
D.1 – Information sharing and privacy
Information sharing with the Federal Government
A certain amount of information sharing and cooperation would be required between the federal
government and the Alberta government to facilitate the establishment and operation of an APP. (To
a lesser extent, the cooperation of the Québec government would also be required. The CPP already
includes certain provisions that permit Canada to enter information-sharing agreements with a
provincial pension plan (see CPP Act, ss. 80, 105 and 113(3).)
Section 113(3)(b) of the CPP Act provides that, where a province gives notice of withdrawal from the
CPP,
[…] the Minister, with the approval of the Governor in Council, may on behalf of the
Government of Canada enter into an agreement with the government of that province
[…]
(b) generally for the making of all such arrangements as may be necessary to permit
provision to be made for the assumption, under the provincial pension plan referred to
in the notice, of all obligations and liabilities [that the provincial plan must assume under
the CPP Act].
In other words, the CPP Act recognizes that some “arrangements” will be “necessary” to permit Alberta
to administer its replacement pension plan.
The CPP’s amending formula – which requires the consent of two thirds of “included provinces,”
representing two thirds of all included provinces’ population – is only triggered by certain types of
amendments. Any amendments necessary to allow the federal government to assist with
administering an APP would not appear to trigger the amending formula and would therefore not
require provincial consent. 34
There is no positive obligation on the Government of Canada to share information collected in

connection with the administration of the CPP with the provinces. However, discretionary information
sharing with provinces that provide or intend to provide a comprehensive pension plan is
contemplated by certain sections of the CPP Act.
Section 113(3) of the CPP Act addresses information sharing by the Minister of Employment and
Social Development (MESD), who is responsible for the administration of the CPP, with the approval
of the Governor in Council with provinces that intend to establish a comprehensive pension plan. It
provides (emphasis added):
34
As described above, the amending formula is triggered by amendments affecting the general level of benefits or classes of benefits
provided by the CPP Act; the contribution rates for employees, employers or the self-employed; the formulae for calculating contributions
and benefits; the management or operation of the CPP Account or Additional CPP Account; or the CPPIB Act: CPP Act, s. 114(4).

Where notice in writing has been given to the Minister 35 by the government of a province as
described in the definition province providing a comprehensive pension plan in subsection
3(1), the Minister, with the approval of the Governor in Council, may on behalf of the
Government of Canada enter into an agreement with the government of that province,
(a) for the furnishing of that government under prescribed conditions with any information
obtained under this Act, including records of any amounts that are shown in the Record of
Earnings to the accounts of persons who have made contributions under this Act in respect of
employment in that province or as persons resident in that province in respect of self-employed
earnings; and
(b) generally for the making of all such arrangements as may be necessary to permit provision
to be made for the assumption, under the provincial pension plan referred to in the notice, of
all obligations and liabilities accrued or accruing as described in paragraph (b) of the definition
province providing a comprehensive pension plan in subsection 3(1).
Section 105 of the CPP Act addresses ongoing information sharing between MESD and provinces
that provide a comprehensive pension plan. It provides (emphasis added):
The Minister may, on behalf of the Government of Canada, enter into an agreement with the
government of a province providing a comprehensive pension plan
(a) under which any information obtained under this Act, including records of any amounts that
are shown in the Record of Earnings to the accounts of individuals who have made
contributions under this Act and under the provincial pension plan of that province and that
relate to the contributions made by those individuals under this Act, may be made available
under prescribed conditions to the appropriate authority of that province having the
administration of the provincial pension plan, and under which any information obtained under
the provincial pension plan may be made available on a reciprocal basis to the Minister; and
(b) under which the Minister or the appropriate authority of that province, in accordance with
any terms and conditions that may be specified in the agreement, may make available to any
individual who has made contributions under this Act and under the provincial pension plan a
statement of any amounts shown in the Record of Earnings or the appropriate records
established under the provincial pension plan, as the case may be, to the account of that
individual, and may act on or give effect to any request made by that individual for
reconsideration by the Minister or the appropriate authority, as the case may be, of any
statement made available to the individual.
Additionally, section 80(1)(d) of the CPP Act provides authority for the MESD to enter into an
agreement with the appropriate authority of a province providing a comprehensive pension plan to
provide for the administration and coordination of the CPP and the provincial pension plan in respect
of persons who are contributors under the CPP or provincial plan in both, including the exchange of
information obtained under the CPP or a provincial pension plan as is necessary to give effect to the
agreement.
The term “information” is not explicitly defined in the CPP Act.
35
For the purposes of this section, Minister refers to MESD.

Department of Employment and Social Development Act
The Department of Employment and Social Development Act (DESDA) is the enabling statute for
Employment and Social Development Canada (ESDC). Part 4 of the DESDA sets out the rules that
apply to the protection and making available of information that is obtained by the ESDC or the
Canada Employment Insurance Commission under a program (which would include the CPP), or that
is prepared from that information.
“Information” is defined at section 30 of the DESDA to mean “personal information” as defined in

section 3 of the Privacy Act (with certain exclusions).
Section 32 of the DESDA provides that information is privileged and may not be made available unless
(emphasis added):
(a) it is authorized under subsection 28.2(5) or by this Part, or by an agreement under section 105 or
paragraph 107(1)(a) of the Canada Pension Plan or paragraph 40(1)(a) of the Old Age Security
Act;
(b) it may be made available under any of paragraphs 33.1(a) to (c) of the Old Age Security Act.
Accordingly, DESDA gives MESD the legal authority to make information in its custody and control as
a result of administering the CPP available to a province that has entered into an agreement under
section 105 of the CPP Act. Interestingly, DESDA does not give MESD the express legal authority to
make such information available under section 113(3) of the CPP Act (likely because information
sharing under section 113(3) requires the approval of the Governor in Council).
However, section 36 of DESDA also permits information to be made available to the government of a
province, or to a public body created under the law of a province, for the administration or enforcement
of a federal law or activity or of a provincial law or prescribed provincial activity, if MESD considers it
advisable and the information is made available subject to conditions that are agreed on by MESD
and the government or body. Information obtained by a government or body under this section may
not be made available to any other person or body unless MESD considers it advisable, the
information is made available for the same purpose and is subject to agreed-upon conditions. Section
36.2 provides a similar right for MESD to share information with any person or body for similar
purposes and subject to similar conditions.
Section 37 of DESDA provides that MESD may, subject to certain conditions, disclose information if
MESD is of the opinion that the public interest outweighs any potential invasion of privacy or permitting
disclosure would clearly benefit the individual to whom the information relates.
Privacy Act
Both the CRA and the ESDC are “government institutions” subject to the Privacy Act. Accordingly,
personal information under the control of the CRA or ESDC as a result of administering the CPP
cannot be disclosed except in accordance with the disclosure authorities provided for in the Privacy
Act. Section 8(2) of the Privacy Act permits disclosure:
(a) for the purpose for which the information was obtained or compiled by the
institution or for a use consistent with that purpose;
(b) for any purpose in accordance with any Act of Parliament or any regulation
made thereunder that authorizes its disclosure;
[…]
(f) under an agreement or arrangement between the Government of Canada or
any of its institutions and the government of a province […]

Accordingly, the Privacy Act would permit MESD to share personal information with a province where
authorized by the CPP and DESDA, or pursuant to an agreement with the province.
Information technology and information security requirements

Neither the CPP, DESDA nor the Privacy Act currently impose specific information technology or
information security requirements on information or personal information.
There are several Treasury Board Secretariat (Canada) (TBS(C)) Policies related to collecting, using,
disclosing, retaining, and transferring personal information held by federal government institutions.
For instance, the Policy on Privacy Protection 36 is intended to ensure effective protection and
management of personal information by identifying, assessing, monitoring and mitigating privacy risks
in government programs and activities involving the collection, retention, use, disclosure and disposal
of personal information. This policy requires (among other things) privacy impact assessments for all
new and modified programs involving personal information. Accordingly, it is likely that MESD would
be required to undertake a privacy impact assessment before entering into any information sharing
agreement with a province.
The TBS(C) Policy on Government Security 37 requires each government institution to meet specific
security and identity management standards. For example, the policy requires government institutions
to address a specific list of security controls including: security screening, information technology
security requirements, physical security requirements, business continuity management, information
management security, security requirements associated with contracts and other arrangements,
security event management, and security awareness training. Accordingly, it is likely that MESD would
incorporate information security requirements consistent with this Policy into any information sharing
agreement with a province.
Data privacy and security

If Alberta is to withdraw from the CPP, consideration will have to be made for the application of privacy
and data security law to the provincial counterpart to the CPP, and to any obligations that would fall
to the province as a result. Personal information required to administer the CPP is collected, used,
and disclosed by ESDC and CRA pursuant to authorities provided under the CPP Act, DESDA, and
their regulations. Both ESDC and the CRA are deemed “government institutions” under the Privacy
Act and are subject to that act’s obligations with respect to protecting personal information. The CRA
and ESDC are also subject to TBS(C) policies and directives on privacy and information security.
In addition to the privacy protections afforded by the federal Privacy Act, CPP information is deemed
“privileged” under DESDA and subject to additional protections.
However, detailed below, the Canada Pension Plan explicitly contemplates that the MESD may enter
into agreements with provinces providing or intending to provide a comprehensive pension plan (i.e.,
a plan equivalent to the CPP) to allow for information sharing on a reciprocal basis.
36
https://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12510
37
https://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=16578

Alberta public bodies are subject to the Alberta Freedom of Information and Protection of Privacy Act
(FOIP). The FOIP restricts the purposes for which Alberta public bodies may collect personal
information and the circumstances in which personal information may disclosed. It also requires that
personal information be collected directly from the individual, subject to limited exceptions. If an
Alberta pension plan is established, the legislation that establishes this plan should include an explicit
authority to collect personal information from and share personal information with the Government of
Canada as necessary to administer the plan. Examples of such a collection authority can be found at
Division III of the QPP Act or section 60 of Ontario’s repealed Retirement Pension Plan Act
(Strengthening Retirement Security for Ontarians), 2016.
The Government of Alberta and the Government of Canada will need to enter into an information
sharing agreement that governs the sharing of information between the two governments in
connection with the administration of an Alberta Pension Plan and Canada Pension Plan. Both
governments will likely need to conduct a privacy impact assessment before entering into any such
agreement. 38 Any information sharing agreement is likely to include provisions relating to information
security.
There is no indication from available guidance that the Government of Canada would be concerned
about data residency issues.
Personal information banks

The Privacy Act generally requires federal government institutions to include personal information in
“personal information banks” (PIBs). Information about PIBs is made publicly available, including the
purposes for which the information in the PIB is used and disclosed.
There are several PIBs relevant to the CPP. For example, ESDC maintains the Canada Pension Plan
Program PIB. The published description of this PIB states that it includes personal information that is
related to administration of the CPP and that this information may be used to administer CPP benefits.
Information in this PIB may be shared in accordance with legislation and/or information sharing
agreements with the Government of Québec for the administration of the QPP and the coordination
of the QPP and CPP programs and with the Revenu Québec for the administration of taxation laws.
Information may also be shared in accordance with legislation and/or information sharing agreements
with other institutions for the administration of a prescribed federal or provincial law or activity and
with provincial governments for the administration of their own social programs and public bodies who
have entered into agreements with provincial governments for the administration of provincial
programs.
This description is arguably broad enough to capture information sharing with the Government of
Alberta for the administration of an APP. However, if specific information sharing arrangements with
Alberta are in place, ESDC may wish to update the PIB description to provide more specific
information about this information sharing (as has been done in respect of the QPP).
The descriptions for other relevant PIBs may also need to be modified to reflect any new information
sharing with the Government of Alberta.
38
TBS’s Directive on Privacy Impact Assessment governs the requirements for these assessments by Government of Canada
departments. Although privacy impact assessments are not strictly required under the Alberta FOIP, the Office of the Information and
Privacy Commissioner of Alberta recommends that they be completed for new projects by public bodies and has published a guide titled
Privacy Impact Assessment Requirements.

Existing relevant Government of Alberta legal authorities and policies
Alberta Freedom of Information and Protection of Privacy Act

The Alberta Freedom of Information and Protection of Privacy Act (FOIP) regulates how “public
bodies,” such as the ATBF, collect, use and disclose personal information.
Section 33 of the FOIP provides at that no personal information may be collected by or for a public
body unless
(a) the collection of that information is expressly authorized by an enactment of Alberta or Canada,
(b) that information is collected for the purposes of law enforcement, or
(c) that information relates directly to and is necessary for an operating program or activity of the
public body.
Section 34(1) of the FOIP requires a public body to collect personal information directly from the
individual, unless an exception applies. Exceptions include:
• Where another method of collection is authorized by the individual, another Act or regulation, or
by the Information and Privacy Commissioner of Alberta; or
• Where the information is necessary (i) to determine the eligibility of an individual to participate in
a program of or receive a benefit, product or service from the Government of Alberta or a public
body and is collected in the course of processing an application made by or on behalf of the
individual the information is about, or (ii) to verify the eligibility of an individual who is participating
in a program of or receiving a benefit, product or service from the Government of Alberta or a
public body and is collected for that purpose.
Section 40(1) of the FOIP sets out the circumstances in which a public body may disclose personal
information, including:
• For the purpose for which the information was collected or compiled or for a use consistent with
that purpose;
• If the individual the information is about has identified the information and consented, in the
prescribed manner, to the disclosure;
• For the purpose of complying with an enactment of Alberta or Canada or with a treaty,
arrangement or agreement made under an enactment of Alberta or Canada;
• For any purpose in accordance with an enactment of Alberta or Canada that authorizes or requires
the disclosure.
Accordingly, in order to ensure that the Alberta public body administering the Alberta pension plan
can collect information from, and share information with, ESDC or the CRA, for purposes relating to
the administration of an APP and the CPP, in compliance with FOIP, the legislation that establishes
an APP should include an express authority for the public body to do so.
An example of such authority can be found at section 211 of the QPP Act, which provides:
An agreement may be entered into with any government for the exchange of
information obtained under this Act and under a similar plan administered by such
government.
Notwithstanding sections 83, 89 and 94 of the Act respecting Access to documents
held by public bodies and the Protection of personal information (chapter A-2.1), such
agreement may provide for the conditions under which a statement of the amounts
shown to the account of a person who has made contributions under this Act and
under a similar plan may be furnished to such person, and, if necessary, be reviewed
on his request.

Further, when the Government of Ontario attempted to establish the Ontario Retirement Pension Plan,
it enacted legislation which explicitly contemplated collection of personal information from the
Government of Canada (see section 60 of the Ontario Retirement Pension Plan Act (Strengthening
Retirement Security for Ontarians), 2016).
Information technology and information security requirements

The FOIP provides at section 38 that the head of a public body must protect personal information by
making reasonable security arrangements against such risks as unauthorized access, collection, use
and disclosure or destruction. The FOIP does not otherwise prescribe specific information technology
or information security measures that must be in place to protect personal information. However, the
Government of Alberta has a number of policies regarding the security of the government’s
information assets, including a Cyber Security Strategy. These policies will need to be considered in
establishing appropriate information security measures for personal information collected, used and
stored in connection with the APP.
Concerns the Government of Canada may raise when negotiating an information sharing
agreement
Policy on information sharing agreements

TBS(C) has published Guidance on Preparing Information Sharing Agreements Involving Personal
Information. This guidance is intended to be used by all federal government institutions subject to the
Privacy Act when considering and developing information sharing agreements (ISAs) with other
governments within Canada and across international borders.
Based on this guidance, before entering into an ISA with the Government of Alberta regarding sharing
CPP related information, the Government of Canada will likely consider:
• The purpose of the ISA
• The legal authorities permitting the exchange of personal information (collection, use and
disclosure) between the parties, including relevant program legislation
• The elements of personal information that will be disclosed and collected
• Where possible, the position and titles of officials who will have access to the personal information
that will be shared
• Whether any consents or any notices to individuals are required
• Any limitations on the subsequent use and disclosure of personal information shared between the
parties to the agreement, subject to applicable laws in each jurisdiction
• All the administrative, technical and physical safeguards required to protect the personal
information shared against accidental or unauthorized access, disclosure, use, modification and
deletion from initial transfer to final disposition
• Processes for addressing privacy or security breaches including notification requirements
• Processes to be used to ensure that the personal information shared is kept accurate, complete
and up-to-date by all parties involved
• The maximum retention period for the personal information shared by the parties and the
disposition methods required
• Where possible and applicable, processes to be used to address individuals' access rights to their
personal information, including rights to request correction
• Processes for compliance monitoring and audits
• Procedures to modify and/or to terminate the agreement
• Conflict resolution mechanisms
• Where applicable, measures to address potential privacy risks posed by anti-terrorism legislation
in a foreign country

• Where applicable, requirements to abide by specific provisions of specific mutual legal assistance
treaties or other international agreements
• Human rights considerations
Further, as noted above, a privacy impact assessment would likely need to be completed by ESDC
about how it would share personal information with the Government of Alberta to support an APP.
Alberta guidance for developing personal information sharing agreements

The Government of Alberta has a similar Guide for Developing Personal Information Sharing
Agreements. Examples of the recommendations set out in the guide, for Alberta public bodies
considering entering into ISA include:
• Ensuring that there is authority for the sharing of personal information
• Forwarding to the Office of the Information and Privacy Commissioner of Alberta a copy of the
proposed agreement and/or the preliminary assessment for review and comments at least 60 days
prior to signing
• Ensuring that only the personal information necessary to enable the public body to carry out the
purposes in the agreement is collected, used and disclosed through the agreement
• Notifying the public or any affected group about the agreement (for example through signage in
the public body’s offices, notices placed with program information on web sites, in brochures, or
on benefit cheque inserts) and, if the sharing involves an ongoing matching program, add a
description of the program to the relevant personal information bank(s)
Accordingly, the Government of Alberta will likely need to conduct its own privacy impact assessment
of any planned information sharing with the Government of Canada to support an APP.

D.2 – Roles of other provinces in CPP
withdrawal and amendment
Statutory withdrawal procedure
Under the CPP, Alberta is entitled to withdraw from the CPP if it meets the requirements outlined
below. The other provinces are not legally entitled to a formal role in the withdrawal process or a veto
over the withdrawal.
The CPP Act allows a province to withdraw from the CPP if it establishes its own pension plan that
meets the following requirements, which are set out in section 3(1). The provincial plan must provide
for:
1. contributions to the plan beginning in the third year following the year in which the province gave
notice of its intention to withdraw from the CPP;
2. the payment of benefits “comparable to those then provided by this Act” or by any other provincial
pension plan (i.e., the QPP); and
3. the assumption of “all obligations and liabilities accrued and accruing” – up to the first day of the
third year following the year the withdrawal notice was given – relating to “the payment of benefits
under this Act attributable to contributions made under this Act in respect of” both
a) employment in the province; and
b) self-employed earnings of persons resident in the province.
The CPP Act requires a provincial pension plan to provide “comparable” – but not necessarily identical
– benefits to those then provided by the CPP or QPP. As a result, the better view is that Alberta would
have some flexibility in the design of an APP’s benefits, including flexibility to provide benefits superior
to the CPP’s to the extent possible.
If a province seeks to establish a pension plan meeting the above requirements, then it may trigger
the CPP’s withdrawal procedure. The CPP’s withdrawal procedure is as follows:
1. The government of the withdrawing province provides written notice to the federal Minister of
Employment and Social Development of the province’s intention to establish a pension plan
meeting the above requirements (s. 3(1)(b)).
2. The province must then provide by law for a pension plan meeting the CPP’s requirements by no
“later than twelve months before the first day of the third year following the year in which notice”
was given (s. 3(2)). In effect, this means that the province has the full year following the year it
gave notice to establish the pension plan.
3. If the province has provided by law for a pension plan meeting the CPP’s requirements by the
deadline, the federal government is required to allow the withdrawal: “the Governor in Council
shall, by regulation made on the recommendation of the Minister of Employment and Social
Development for the purposes of this CPP, prescribe that province as a province [providing a
comprehensive pension plan]” (s. 3(2)) (emphasis added).
4. The regulation prescribing the province as “a province providing a comprehensive pension plan”
becomes effective on the first day of the third year following the year in which the province gave
the withdrawal notice (s. 3(3)).
5. When the regulation becomes effective, the requirements for employers, employees and the self-
employed to make CPP contributions no longer apply in the province (s. 4(1)).

The CPP Act does not entitle other provinces to a formal role in Alberta’s withdrawal from the CPP.
However, that would not stop the federal government from consulting or involving other provinces as
it saw fit. We are not aware of any formal agreements between Canada and the CPP participating
provinces that would supplement the CPP’s withdrawal procedure or entitle other provinces to a formal
role in Alberta’s withdrawal from the CPP.
A province may withdraw from participation in the CPP if it is a “province providing a comprehensive
pension plan.” To qualify as such, the CPP requires that the withdrawing province provide a provincial
“plan of old age pensions and supplementary benefits” that meets certain prescribed requirements.
In order to qualify as a provincial counterpart to the CPP, a comprehensive provincial pension plan
must do all of the following:
1. Provide participants with some form of old age pension and supplementary benefits;
2. Be a contributory plan;
3. Commence in the third year following the provision of notice under subsection 3(1) of the CPP
(the “Effective Withdrawal Date”);
4. Provide benefits that are “comparable” either to those provided under the CPP or to those provided
under the QPP (being the only extant provincial counterpart to the CPP); and
5. Assume “all obligations and liabilities accrued or accruing” of the CPP attributable to CPP
contributions in respect of employment and self-employment in the province to the Effective
Withdrawal Date.
Following the provision of notice under subsection 3(1) of the CPP Act, the legislature of the
withdrawing province must provide for the establishment and operation of a pension plan that meets
the aforementioned criteria by no later than twelve months before the Effective Withdrawal Date.
Where a province has done so, the federal Governor in Council is required to prescribe the
withdrawing province as a “province providing a comprehensive pension plan” by regulation made on
the recommendation of the Minister of Employment and Social Development, effective as of the
Effective Withdrawal Date. 39
Once the withdrawing province has given notice to the federal Minister of Employment and Social
Development pursuant to subsection 3(1)(b) of the CPP Act, the Minister may, with the approval of
the Governor in Council, enter into an agreement with the government of the withdrawing province on
behalf of the Government of Canada to facilitate a transfer of CPP obligations and liabilities.
Under subsection 113(3) of the CPP Act, the government of Canada may enter into an agreement
with the withdrawing province for the provision of information to the province and to make whatever
arrangements may be necessary to provide for the assumption of all CPP obligations and liabilities
accrued or accruing in respect of employment and self-employment in the withdrawing province. 40
39
CPP Act, ss. 3(2) and (3). For an example of such a regulatory prescription, see the Prescribed Province Pension Regulations.
40
CPP Act, s. 113(3)(b).

Liabilities
After a province is prescribed as “providing a comprehensive pension plan,” the CPP Act addresses
the obligations and liabilities that the provincial plan had to assume, under section 3(1), in order for
the province to withdraw. Such obligations cease to be obligations or liabilities accrued or accruing
with respect to the payment of benefits under the CPP attributable to contributions made under the
CPP in respect of employment or self-employment in the province (s. 113(1)(a)).
Assets
The CPP requires the federal Minister of Finance to pay the withdrawing province its proportionate
share of the CPP assets, as determined by the formula in section 113 of the CPP Act.
The CPP Act does not compel the federal government to negotiate with a withdrawing province over
the division of the CPP’s assets and liabilities. Rather, the CPP defines the division, albeit at a high
level. Finally, we note that the division of assets and liabilities could be affected by a federal-provincial
agreement. We are not aware of any such agreement.
CPP amendment procedure

The CPP Act restricts the federal government’s ability to make certain changes to the CPP unilaterally.
Any amendment or enactment that affects the substance of CPP contribution rates or benefits levels,
or the operations of the CPP accounts or CPPIB, requires the consent of a two-thirds of the included
provinces with two-thirds of the population of all included provinces. In the event that any such
significant amendment to the CPP is required, the amendment would be subject to the following
consent rules.
Consent requirement
Under section 114 of the CPP Act, an amendment or enactment of Parliament that affects the matters
described below requires the consent of the lieutenants governor in council of provinces that comprise
(a) at least two thirds of the included provinces, and (b) at least two-thirds of the population of all of
the included provinces. 41 As described further below, all provinces including Québec are “included
provinces” under section 114(1) of the CPP Act, but the territories are not included.
Such consent is required for any provision of any enactment of Parliament that alters (whether directly
or indirectly, and whether immediately or in the future) any of the following (subject to certain limited
exceptions):
• The general level of CPP benefits;
• The classes of CPP benefits;
• The CPP contribution rate, first additional contribution rate or second additional contribution rate
for employees, employers or self-employed persons for any year;
• The formulae for calculating CPP contributions and benefits;
• The management or operation of the base CPP account or the additional CPP account; and
• The CPPIB Act.
41
CPP Act, s. 114(4). For the purposes of obtaining consent, provincial populations are determined in aggregated by Statistics Canada as
of June 1st of the year in which the enactment is made (see CPP Act, s. 114(5)).

Notice requirement
Before certain types of amendments can be passed, “notice of intention to introduce a measure
containing” such an amendment must be laid before Parliament. 42 Such notice is required in respect
of any amendment that,
“[…] alters, or the effect of which is to alter, either directly or indirectly and either
immediately or in the future, the general level of benefits provided by this Act or the
contribution rate, first additional contribution rate or second additional contribution
rate for employees, employers or self-employed persons for any year […].” 43
The notice of intention must be presented in a form, “[…] sufficient to indicate the nature of the
provision contained or proposed to be contained in the measure […].” 44 Upon such a notice being laid
before Parliament, the Minister of Employment and Social Development must send a copy of the
notice to the lieutenant governor in council of each included province (as defined above). 45
An amendment that triggers the notice requirement cannot come into force earlier than the first day
of the third year following the year in which notice is given of the intent to introduce the measure
before Parliament.
42
CPP Act, ss. 114(2) and (3).
43
CPP Act, s. 114(2).
44
CPP Act, s. 114(3).
45
CPP Act, s. 114(2).

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What are the main features of an Alberta Pension Plan discussed in the report?

What are the main features of an Alberta Pension Plan discussed in the report?

What is the process for withdrawing from the Canada Pension Plan?

What is the process for withdrawing from the Canada Pension Plan?

Alberta Pension Plan –

Analysis of Costs, Benefits,

History and features of CPP ....................................................................................................... 6

Key features of an Alberta Pension Plan................................................................................... 8

Process for withdrawing from the CPP ................................................................................... 20

Transition considerations ........................................................................................................ 22

Delivering an APP ..................................................................................................................... 26

Opportunities for additional analysis ...................................................................................... 35

Appendix A: Additional considerations for an APP ............................................................... 38

Appendix B: Additional discussion of Asset Transfer from CPP to an APP ........................ 47

Appendix C: Detailed APP financial results and actuarial model .......................................... 53

Appendix D: Additional legal and governance considerations ............................................. 82

Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | i

The key questions considered in this report are:

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Table 1 – Comparison of contribution rates under an APP and the CPP

Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 2

What are the considerations for a successful transition to an APP?

How would the establishment of an APP affect other government programs?

Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 3

Respectfully submitted on behalf of LifeWorks,

[Redacted to protect privacy - Original signed]

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Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 5

Additional CPP overview

Level of initial benefits

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Discussion Box 1: Contribution rates

Initial contribution rates

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Table 3 – Comparison of Additional APP/CPP minimum contribution rates

Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 11

Long term nature of the projection

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Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 14

Table 5 – Summary results – Alternate population and economic growth scenarios

Target A/E Ratio 22.5 23.6 26.2

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Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 16

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Sensitivity of the contribution rates to assumptions used

Contribution rates under potential adverse scenarios

Table 6b – Sensitivity of contribution rates to potential adverse scenarios

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Provide comparable benefits to the CPP

Assumption of obligations and liabilities

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Alberta Pension Plan – Analysis of Costs, Benefits, Risks and Considerations | 21

Table 7 – Transition activities

These key activities will be discussed in more detail below.

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