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The importance of strong governance for pension and benefits plans

Updated: April 17, 2025

The rapid advancement of technology and continuous changes in regulations have increased risks and threats for pension and benefits plans. As a result, the importance of strong governance cannot be overstated.  

As the industry sets higher expectations for the level of involvement from those charged with governance (TCWG), it becomes imperative to ensure that these plans are managed with the utmost diligence and that appropriate documentation supports the involvement of TCWG. This is where enterprise risk management (ERM) plays a crucial role. 

Elevating governance standards

While the ultimate fiduciary responsibilities of TCWG remain relatively unchanged, the complexity of the industry has evolved. As a result, additional levels of risk assessment and the establishment of corresponding processes and controls over key areas such as financial reporting, ensuring compliance with regulatory standards, and the need to manage the plan’s ability as a going concern are required.  

While TCWG may call upon service providers to assist with the execution process, the requirement to validate the consistent application of processes and controls in the risk management process cannot be transferred. This results in a heightened level of involvement from TCWG for maintaining the trust and confidence of plan participants and stakeholders. 

The role of ERM

ERM is a comprehensive approach to identifying, assessing, and managing risks that could impact the achievement of an organization's objectives. For employee benefits plans, ERM is vital in ensuring that potential risks are proactively managed and mitigated. This includes market volatility, demographic changes, and regulatory shifts.

By integrating ERM into the governance framework, boards can enhance their ability to make informed decisions that safeguard the long-term sustainability of employee benefits plans. This may also allow for clear alignment of processes and controls to safeguard against the identified risks.

Improving documentation and validation

One of the key aspects of strong governance is the ability to validate the decisions made by TCWG. Here are some suggestions to improve documentation and ensure robust validation:

Maintain detailed records of all board meetings, including minutes, agendas, and supporting documents. This ensures transparency in the decision-making process and provides a clear audit trail for all decisions made. Key actions in the role of TCWG in this process include the documentation of discussions around the risk evaluation, assessment, and management within the plans. Fraud risk continues to be a heightened topic of discussion and involvement from TCWG in assessing this area is also important. 

If you are unsure where to begin on your governance journey, you may consider the use of internal and external audits to assess the effectiveness of governance practices and identify areas for improvement. This helps in maintaining accountability and ensuring compliance with regulatory requirements. A governance review by risk specialists allows you to assess gaps in your current process and control environment and help determine if you need to action change.

Develop and document clear policies and procedures for all aspects of plan management, including investment strategies, risk management, and compliance. This provides a consistent framework for decision-making and helps in aligning TCWG's actions with the plan’s objectives.

Engage with plan participants, employers, and other stakeholders to gather feedback. Ensure their interests are considered and their expectations are met in the decision-making process. This fosters trust and enhances the board's ability to address the needs of all stakeholders. 

Provide ongoing training and development opportunities for board members to ensure they are well-equipped to fulfill their governance responsibilities. This includes staying up to date with industry best practices and regulatory changes. Being aware of industry resources and reading up on recent developments, such as Canadian Association of Pension Supervisory Authorities (CAPSA) guidelines, is a great way to stay informed. For example, CAPSA Guideline 10, Guideline for Risk Management for Plan Administrators, was recently released in September 2024.

Trustees’ responsibilities

The role of trustees in the governance of pension and benefits plans is more critical than ever. As the landscape of risks and regulatory requirements continues to evolve, trustees must take an active role in both governance and risk management. This proactive involvement is essential to ensure that the plans are managed with the highest standards of diligence and accountability. By integrating ERM into their governance framework, trustees can better identify, assess, and mitigate potential risks, thereby safeguarding the long-term sustainability of the plans.  

Active participation in risk management not only enhances decision-making but also fosters transparency and trust among all stakeholders. It is through this dedicated and engaged approach that trustees can truly fulfill their fiduciary responsibilities and maintain the confidence of plan participants and stakeholders. 

How we can help

It’s important for pension and benefits plans to implement good governance practices. Our industry-focused teams have extensive experience assessing processes and controls in an employee benefit plan environment. If you would like assistance in developing risk management and governance processes or would like to perform testing on existing processes and controls, please contact us.

David Veld
Partner, National Pension and Benefits Leader
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Krista Tartaglia
Partner, Pension and Benefits Operational Excellence Leader
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