September 29, 2023
Submission on CAPSA Guideline for Pension Plan Risk Management for Plan Administrators
The Canada Climate Law Initiative appreciates the ambitious nature of the Canadian Association of Pension Supervisory Authorities (CAPSA) Guideline for Pension Plan Risk Management for Plan Administrators, covering foundational pension risk management concepts, including environmental, social, and governance (ESG) considerations, leverage, cybersecurity, investment risk, and use of third parties, all of which are currently priorities for pension trustees and administrators when fulfilling their fiduciary duties and statutory standard of care appropriately. Our comments in this submission address one aspect of the Guideline, specifically, guidance related to management of climate-related financial risks.