:
You want to do section by section.
Are you okay with that, Guy?
The first section deals with the letter received by the chair from Michael McLeod, member of Parliament for the Northwest Territories, about the Honourable Robert McLeod, Premier of the Northwest Territories, requesting to meet during the week of November 21, 2016. It was agreed that the chair would write back indicating the committee's interest in hearing from him about their priorities but at a later date, perhaps during next year's pre-budget consultations.
The letter we received was mainly about pre-budget consultations for this year. Those meetings are already over. The report is being drafted—and I know it is the premier, representing a territory—so we would have to set up a special meeting to do so. We feel that if it's going to deal with budget matters, it would be better in pre-budget consultations next time around.
Ron.
:
We did not go up north, and I think while he's not a representative of the Yukon or Nunavut, at the same time he still represents a very important one third of our northern country.
We often use the expression “coast to coast to...coast”—I put the pause in there for the blues—but it's important to recognize, I think, that perhaps there is still more we could be doing.
To me, waiting another year is too long, because if we wait until the fall of next year, essentially that's another 10 months. Whether we have a special meeting to hear from the Premier of the Northwest Territories about the issues facing the Northwest Territories, to have on the record some special consideration of what's going on up north, with issues not only of suicide but also of transportation and energy, I think we could find an hour for this gentleman.
If we can find an hour for the chair of the Economic Council of Canada to testify from South Korea, I'm sure if the premier is willing to come here to Ottawa in the week of November 21, we could at least hear him out, ask a few questions, and gain a better understanding of one of the only territories in the country where the federal government has a direct responsibility for almost all of the services.
:
I think probably procedurally the best way to proceed is we need basically an agreement to adopt the subcommittee report, and if there's anything we want to pull out of it and deal with differently we can do that. Perhaps I could finish quickly going through the report and then come back to those sections that people want to deal with separately.
The second section really deals with the procedure and how we would deal with Bill , which is the amendments to the Canada Pension Plan, the schedule that we would set up. It's listed on the paper.
The third section lays out, on a motion from Steven MacKinnon, the procedure that would be followed relative to votes on Bill .
The fourth section lays out the plan of the committee to deal with Bill , a second act to implement certain provisions of the budget tabled in Parliament on March 22, 2016, and other measures. That procedure on timing is laid out there.
The fifth section in the subcommittee report points out that we agreed to a motion by Steven MacKinnon that lays out how we would consider Bill and when the votes would have to take place.
The sixth section is laying out that in relation to the pre-budget consultations on the 2017 budget, if we can find the time, the committee would convene an in camera post-mortem meeting before the holiday break to discuss this year's progress and how we could do it differently.
The seventh section of the subcommittee report talks about how we would deal with Bill , an act to amend the Income Tax Act (tax credit—first aid), which was referred to the committee on October 26, 2016, and that the committee consider this bill at the end of January or in February 2017, as the bill must be reported back to the House for March 23, 2017.
That's the subcommittee report. Have we got agreement on that?
You want to come back and deal with the first section, I gather? Okay.
Dan.
My concerns with this motion, as it stands, are twofold. One is that we understand the report isn't finalized, it was only the release of the first three ideas. It might be premature, but we can figure that out.
The other issue I have, which is the bigger issue, is this that is an advisory council to the minister. Mr. Barton pointed out that they may make recommendations, but the government may have no intention of taking it on or moving forward. I wouldn't want to waste the committee's time on studying something that the government, for whatever reason, may not move forward with.
I don't disagree with it in terms of if there was a recommendation that the government move forward on, and we look at that, but as this motion stands right now, my concern would be that to look at everything might not be the best use of this committee's time. It is already quite limited, given the amount of work we have, so I would focus more on whatever the government wants to actually propose versus an advisory council, which may or may not have the government's support in terms of each specific plan.
I have more of a practical comment. As Mr. Sorbara, said, we have a number of studies that have been approved and others we need to consider. That includes a motion from Mr. Albas, I believe, on the de minimis threshold. We still have two full studies of bills left to do, as well as another study after the holidays.
Between now and when we examine the recommendations in the minister's advisory council report, the committee will have a number of other reports and many other government policies to deal with. For that reason, not only do I think the effort would be premature, but I also think it would impede other work that has already been approved by the committee.
I think the Advisory Council on Economic Growth plays a pivotal role in the policy directions the government is taking right now. You don't appoint 14 people of that calibre simply to have them engage in theoretical discussions that bear no fruit.
A three-part report has already come out. I think it would be worthwhile to spend at least one meeting, if not two, taking a meaningful look at the recommendations in the report, especially if the government is showing an interest in moving in that direction. The benefit would be in meeting with people to whom we could put those questions.
I wholly understand the idea of discussing specific issues, but who are we going to invite to discuss those issues with?
I'm not so sure we'll be able to find people with whom we can have those discussions, unless the minister is willing to spend two days with us answering our questions on the subject. Even then, we would be getting only the minister's viewpoint and not a broader perspective.
For those reasons, I think it would be beneficial for the committee to hear directly from the council on the logic behind its recommendations, which the government is currently considering and, according to the economic update, is going to implement.
I am wholly in favour of the motion and hope that it will be adopted. We could find time to deal with the matter after the holidays. We have a good bit on our plate, yes, but in January and February, leading up to the federal government's budget announcement, we have a bit of latitude.
I know we have quite a few studies before us. We have many irons in the fire, as they say, but that's no reason to relegate crucial issues to the back burner.
The government decided to establish the Advisory Council on Economic Growth, which, strictly speaking, we are not opposed to. There can never be too much goodwill brought to bear when making the big decisions affecting Canada's economy, the decisions delivering the greatest economic benefit and stimulus. That said, this is a new component. We should not think of it as an outside body; instead, we should look at it as a new body, one worthy of sober, serious, constructive, and, above all, proper consideration by the committee.
Doing that means taking the time to carefully examine each of the recommendations made. That would help not only the committee, but also the government. With a view to identifying the best possible ways to foster growth and prosperity, the government would certainly benefit from the insight and more detailed explanations by the advisory council that such an analysis by the committee would offer.
Of course, we all have our own political visions or agendas, not to mention biases against and in favour of certain approaches. That does not mean, however, we should not do what we can to shed light on these elements, in the most meaningful, enriching, and comprehensive way possible so that we, as parliamentarians, can gain a crisper understanding of the issues we care about. The other goal would be to help the government better understand the issues brought to its attention and the decisions it will have to make.
We believe this motion should be adopted and that it does not prevent the committee from studying the bills as planned. That is the regular or traditional work of the parliamentary committee. It goes without saying. This is not at all a matter of pushing our studies of the bills aside. That is part of our job.
In a nutshell, I think this is an important analysis, one that could benefit all Canadians. We are talking about a non-partisan exercise given that the government, in creating this advisory council, sought the counsel of people who do not belong to political parties. Therefore, we believe this motion should be adopted.
:
Thank you very much. I appreciate the opportunity to speak to this.
We know something for sure, and I believe this motion is beyond partisanship, because the aim of it is to be able to have a good understanding of economic growth. What we have seen, and without having to point any fingers toward any party, is that the indication is not there, the real measures are not there. We're going into a chaos of back-and-forth on where the numbers are, where the economic growth is, where the job growth is, and all this kind of stuff.
This is a fantastic idea. It has become very handy for the committee and for the to make the best judgments on moving forward, because those measures are the real measures we can build on for the future outlook, for the budget, for spending, and for moving forward on more stable ground.
I have one last question about Bill . I'd like to know whether the Liberals and Conservatives still have no plans to call any witnesses for the committee's study. On our side, we have witnesses we would like to invite.
I had suggested that the committee invite witnesses who could speak to the technical aspects, not those who would argue in favour of or against the bill. The focus would be on the more technical considerations, such as the changes to the Bank Act and with regard to the
[English]
common reporting standards.
:
Could we come to order, please?
Pursuant to Standing Order 108(2), our subject matter today is Bill . We have with us witnesses from the Department of Finance, the Canada Revenue Agency, the Department of Employment and Social Development, and the Office of the Superintendent of Financial Institutions.
I think at the steering committee we had asked that there be separate hearings, but we agreed to just put everybody in the mix. If we can get done a little earlier, we will.
The floor is yours, Mr. Purves.
:
Thank you very much, Chairman.
Good afternoon to all committee members.
As noted, my name is Glenn Purves, General Director of the Federal-Provincial Relations and Social Policy Franch at Finance Canada. I'm joined today by officials from Finance Canada, Employment and Social Development Canada, and the Canada Revenue Agency, as well as from the office of the chief actuary.
Today we're pleased to answer your questions on Bill C-26 or any questions that you may have on the Canada Pension Plan enhancement. I brought copies of the backgrounder that was posted on the Finance Canada website for those of you who want a copy. In addition, I believe our parliamentary secretary circulated for your benefit an additional supplementary document that just gives context on the contribution rate and on the earnings replacement. I was going to suggest just walking through that at the end of my opening remarks so we can position ourselves appropriately on that.
The Canada Pension Plan is a complex program involving three ministers and departments. To situate you, Finance Canada is responsible for leading discussions with provincial officials on possible changes to benefits and contributions. In addition, my department is responsible for the development of policy and legislation on the Canada Pension Plan Investment Board and the Income Tax Act. The Canada Revenue Agency is responsible for the collection and administration of contributions, while Employment and Social Development Canada has significant responsibility for the calculation and payment of benefits to Canadians and for the overall administration of the plan.
You'll also be hearing from the Office of the Superintendent of Financial Institutions, from my colleague Monsieur Montambeault. Their officials provide expert actuarial projections on the financial position of the plan. These projections are most recently contained in the 28th actuarial report tabled in Parliament on October 28, 2016.
I'd like to provide you with a quick walk-through of Bill C-26. The bill proposes amendments to the Canada Pension Plan, the Canada Pension Plan Investment Board Act, and the Income Tax Act consistent with the agreement reached by Canada's ministers of finance on June 20, 2016, to enhance the Canada Pension Plan.
The bill consists of two parts. Part 1 amends the Canada Pension Plan, notably: to increase the amounts of the retirement pensions from one quarter to one third of pensionable earnings, as well as the survivors' and disability pensions and the post-retirement benefits, subject to the amount of additional contributions made and the number of years over which those contributions are made; to increase the maximum level of pensionable earnings by 14%; and to provide for the making of additional contributions, beginning in 2019 and phased in gradually over seven years.
The focus of the enhancement is very much on income replacement. To this extent, it resembles very much a registered pension plan that you would see in the workplace.
[Translation]
Part 1 also amends the Canada Pension Plan Investment Board Act to provide for the transfer of funds between the investment board and a newly created government account for the additional contributions, and to provide for the preparation of financial statements in relation to amounts managed by the investment board involving the additional contributions and increased benefits.
Part 2 makes related amendments to the Income Tax Act to increase the working income tax benefit in an effort to offset the incremental CPP contributions for eligible low-income workers and to provide a deduction for additional employee contributions so that Canadians are not subject to higher costs associated with the after-tax savings plan.
[English]
With that, I'll just walk everyone briefly through this backgrounder that has been circulated. This is the document that has the red and the blue attached in it just so everyone is on the same page.
Let's talk about this in steps. The first step I'm going to walk through is the red and then I'll follow with the blue. In step one, just to configure everyone, figure 1 talks about the contribution rate. Figure 2 talks about the earnings replacement. Contribution rate is the amount that's paid in terms of contributing to the CPP, and the earnings replacement is the amount that is received on the income replacement side. In step one, the first additional contribution rate and the first additional replacement rate would gradually be phased in over the base or existing CPP earnings range from the year 2019 to the year 2023. This is the red. This is the phase that goes from 2019 to 2023 for both the contribution rate and the replacement rate.
:
That's right. It's a gradual phase-in. By 2023 it hits a maturity. For 2024 and 2025 we're talking about the blue section.
So in 2016, for example, the base earnings range maxes out at $54,900. That is the year's maximum pensionable earnings that you see at the top right corner. The YMPE is indexed to wages, so that YMPE will gradually grow over time, but for now it's $54,900.
The first additional contribution rate, the very top figure we're talking about right now, combined employee and employer, would be gradually increased to 2%, and the first additional replacement rate, which is the red box on figure 2, would be gradually increased by 8.3%, thereby increasing the total earnings replacement from the CPP from 25% to 33.3%. If you see in figure 2, that's why, when we speak about it, it's going from one quarter to one third, the replacement rate. So for 2%, increasing by 2%, it covers going from one quarter to one third.
Now in step two, I'll just speak briefly about the blue section here. In step two, a new earnings threshold would be introduced, what we call, for the sake of this discussion, the year's additional maximum pensionable earnings. This is up and beyond what is permissible right now in terms of coverage. So in this case, if you see the blue, the year's additional maximum pensionable earning starts in 2024 and reaches 114% of YMPE in 2025.
The second additional contribution rate, which is figure 1, would only apply to earnings between YMPE and YAMPE, so just between the 100% and the 114%, which in 2016 terms would be earnings between $54,900 and $62,600. So that $62,600 is the $54,900 plus the 14%.
The second additional contribution rate would be 8%. Combined employee and employer, the second additional replacement rate would be 33.33%, as shown. So it would have the equivalent earnings replacement as what is seen on the base side. So we're going from nothing in this case—there's no coverage right now—to one third.
I think we'll leave it there. If there are any further questions on it, I can certainly answer these, or my colleagues can answer these. At the very back there are two tables. I'll start with table 2. Table 2 speaks to the indicative employee contributions to the enhanced portion of CPP—biweekly, nominal, after-tax. So this is every two weeks what the contribution would be. The top table speaks to the additional income or additional earnings that would be achieved at maturity, but in 2016 dollars. So we're not talking 40 years down the line indexed to inflation and so forth. We're bringing it back. It's in 2016 dollars. That is effectively what you're getting in terms of the additional earnings with the contribution that you make.
At any rate, this was passed around to help members in terms of navigating this.
I will start my remarks in French and move on to English.
[Translation]
Mr. Chair and honourable members of the committee, thank you for the opportunity to appear before you today. I am Michel Montambeault, Director of the Canada Pension Plan, known as CPP, and Old Age Security, or OAS, Actuarial Valuations at the Office of the Chief Actuary.
I have here with me my colleague Michel Millette, Managing Director. Michel is involved in the CPP Actuarial Valuations and liaises with the Canada Pension Plan Investment Board, or CPPIB. Michel is also responsible for the actuarial evaluations of the employment insurance, or EI, premium rate-setting and the Canada student loans, CSL, program.
The Office of the Chief Actuary, or OCA, is an independent unit within the Office of the Superintendent of Financial Institutions, or OSFI, that provides a range of actuarial valuation and advisory services to the Government of Canada. While the chief actuary reports to the superintendent of financial institutions, he is solely responsible for the content and actuarial opinions reflected in the reports prepared by the office.
The OCA plays an important role in helping decision-makers’, parliamentarians’, and the public’s understanding of some of the risks associated with the public pension arrangements by providing checks and balances on the future costs of the different pension plans under its responsibility. As part of its mandate, the OCA conducts statutory periodic actuarial valuations of the Canada pension plan, old age security program, federal public sector employee pension and insurance plans, and the Canada student loans program.
Since 2012, the OCA has also been responsible for preparing the statutory actuarial report on the employment insurance premium rate. In addition, for the CPP, whenever any bill is introduced in the House of Commons to amend the plan in a manner that would materially affect the estimates contained in the most recent actuarial report, a supplementary actuarial report must be prepared reflecting the change in those estimates. A similar requirement also applies for other plans and programs. The purpose of all the actuarial valuations is to determine the financial status of the plans and to assist the stakeholders in making informed decisions regarding the financing of the plans.
[English]
Bill provides for the enhancement of the CPP as agreed to in principle by the provincial and federal finance ministers on June 20th. The enhancement increases the replacement level from one quarter to one third of pensionable earnings and increases the upper eligible earnings limit, the year's maximum pensionable earnings, by 14% by 2025. The additional contribution rates required are set at 2% below the year's maximum pensionable earnings and 8% above it, with the rates split evenly between employers and employees. There is a scheduled seven-year phase-in of the enhancement between 2019 and 2025. Under the enhancement, the new benefits will accrue gradually over time, with full accrual occurring by about 2065. Individuals with less than 40 years of contributions will receive partial benefits.
As required by the CPP statute, a supplemental actuarial report, the 28th, on the CPP was prepared to show the effect of Bill on the long-term financial state of the plan. The 28th CPP report was prepared on the basis of the last regular triennial report, the 27th CPP actuarial report as at December 31, 2015. This report pertains to the current or base plan. The 27th and 28th CPP reports were tabled on September 27 and October 28 respectively.
The findings of the 27th report confirm that the legislated combined employer-employee contribution rate of 9.9% is sufficient to financially sustain the base plan over the long term. The legislated rate of 9.9% is higher than the minimum rate to sustain the base plan of 9.79%, as stated in the 27th report. For the enhanced or additional CPP, the 28th report confirms that projected contributions under the proposed legislated first and second additional contribution rate of 2% and 8%, together with projected investment income, are sufficient to fully pay projected expenditures over the long term. The legislated rates are higher than the minimum required first and second additional rates of 1.93% and 7.72% respectively, as stated in the 28th report.
It is important to note that the financing approaches of the base and additional CPP differ. The base plan is partially funded such that contributions are and will continue to be the main source of revenue. In contrast, for the additional plan it is required that projected contributions and investment income be sufficient to fully pay projected expenditures over the long term in order to minimize intergenerational transfers. As such, investment income is the main source of revenue for the additional plan. This means that the minimum required contribution rates for the additional plan are far more sensitive to the rates of return earned on its assets compared to the base CPP.
As shown in the 28th report, for the additional CPP, if the projected real rate of return is reduced by 100 basis points, so that the average real return falls from 3.55% to 2.55%, the minimum additional rates would increase by 32%, exceeding the legislated rates of 2% and 8%—from 1.93% to 2.55% and from 7.72% to 10.2%. In comparison, for the base CPP the same 100 basis-point drop in the projected return for the base CPP, from 3.98% to 2.98%, would result in a projected increase of 8% in the minimum rate, from 9.79% to 10.53%. Although the base minimum rate would also exceed the legislated rate of 9.9%, the relative impact of lower investment returns is much higher for the additional plan, about four times higher than the impact for the base plan.
Thank you for the opportunity to appear before this committee. We would be pleased to answer any questions you might have.
:
Very well. Thank you. That's very important information, and we must keep it in mind during our study of the bill.
Mr. Montambeault, thank you very much. Your analysis was very informative.
I have two questions for you. I'll fire them off one after the other, and then you can take the time you need to answer.
Mr. Machin, from the Canada Pension Plan Investment Board, spoke briefly about the language and provisions in the bill. I think many people are wondering why the office will now have two accounts, one for the current plan and one for the additional plan.
In terms that the people following our proceedings can understand, I would like you to explain why the second account is more dependent on investment returns.
In response to your first question, I said, during my presentation, that the financing approaches of the base and additional CPP were completely different. The base plan is more dependent on contributions because it's not fully capitalized. Conversely, the additional plan relies entirely on the capitalization of contributions.
The base plan is 70% dependent on contributions and 30% dependent on investment income. The additional plan, however, is 70% dependent on investment returns and 30% dependent on contributions. Because of the two different financing approaches, it's important to keep track of each element. That's why there will be two accounts.
Thank you, everybody, for coming today and answering these questions.
The CPP benefits that a person receives are based on an average of what earnings there have been from the time the person is 18 until they retire. To accommodate the periods when a person might have some hiccups—low earnings, or zero earnings—during those years, the plan allows for the lowest eight years of earnings to be dropped out from the calculation. This exemption is referred to as a drop-out.
There are also two other items we have besides the basic exemption that specifically are called drop-outs. One is for disability, and one is for child-rearing. If the person decides to stay home to raise their child, they won't be penalized for during that during their life.
That's in the base plan. When I look in the enhanced plan, I don't see that in there. Is there a reason that's not in there, or did I miss something?
You're correct that the drop-outs still remain in the base plan. With respect to the general drop-out, I can say that it is built into the structure being enhanced, so it's still there. Today, you have a base plan in which your contributions start at age 18 and end at age 65. You're talking about 47 years. You have a general drop-out of 17%, which drops out eight years, so that brings you to your best 39 years. The enhancement doesn't have that drop-out per se, but it takes your best 40 years. It's very similar to the general drop-out that is put in. There's also a plus-65 drop-out. You take in the base plan your contributions above age 65, and you replace your lower earnings prior to 65. That is also built in, because, again, you take your best 40 years.
With respect to the child-rearing and disability drop-outs, they will remain in the base plan and they will still protect individuals for eligibility purposes and continue to enhance their benefit.
With respect to the enhanced portion of the plan, these are not duplicated in the enhanced portion of the plan, as this plan is closely linked to the individual's contributions. As Glenn mentioned before, it's very similar to a workplace pension plan. It aligns with the full funding provisions by minimizing the subsidies and also by minimizing the intragenerational and intergenerational transfers.
:
But eight years could still be substantial in a defined benefit plan. In the military, for instance, it would be equal to around 8% of someone's salary.
I'm a little concerned that we haven't looked at calculating that. I understand there's a child-rearing provision and a general drop-out provision, but I believe if someone and their employer were willing to contribute to the CPP during a certain period when they could show what their salary would be over a certain time, they should still have that ability to contribute to the CPP to ensure they don't lose that long-term buying power.
Obviously the contributions are very important, and I understand we want to have no longer a pay-as-you-go CPP plan but something that's...and we don't want to transfer wealth from one generation to another. At any rate, I hope somehow someone would be interested in looking at that in greater detail, both the actuary and the finance department.
I was wondering if you could give me the additional costs in the form of increased Government of Canada payments to cover the employer portion of the CPP enhancement in relation to federal employees. Around 250,000 public servants are in the employ of the federal government, and I'd like to know how much extra the enhancement is going to cost the federal government. I'd asked this previously and no one got back to me, so I'm asking again.
Thank you to all of our witnesses for the work you do for Canada.
I'm just going to make a quick comment, and then I'll get right into my questions.
Mr. Purves, I appreciate the work you do. However, I would say that, unlike Mr. Montambeault, who actually came and made sure we had a briefing here, it's disappointing when parliamentarians cannot have.... I was able to get a copy of your statement. Part of it is English and part is in French, and I think that puts other members at a disadvantage. I would hope that, in the future, anyone from Finance Canada who comes in will make sure this committee actually has their statements ahead of time so that we can be more informed and ask better questions.
I'll start first in regard to the working income tax benefit on a dollar-for-dollar ratio. Mr. LeBlanc, if someone is, let's say, working, low-income, will they receive that benefit dollar for dollar so that it compensates for any loss of income?
:
Sure. Why don't I take a crack at it and others can complement.
We'll start with the youngest. Given the fact that the implementation period for this CPP enhancement starts in 2019 and leads up to 2025, it's really over a period of 40 years to 50 years that you see this improvement and maturing of the benefits. Someone who is 22, for instance, is at a good age to benefit from the majority of this enhancement. The idea is that this enhancement is really about improving the income replacement for future generations. A lot of this has to do, of course, with concerns about retirement plans, defined benefit plans, shifting out of workplaces, and the efficiency of having a CPP and being able to expand the CPP and the portability of it and so forth. If you're 22, you stand to benefit for almost the maturity, if not the maturity, over that period of time.
For someone who is 55, you will be able to contribute starting in 2019, and as it has been conveyed here, you will get out of it what you put into it in terms of a certain return and a certain benefit. Having said that, the amount that the person of 55 years will receive, the majority of the CPP payment that they get will be on the basis of the base CPP, because the enhanced CPP will not have accumulated as much income replacement for...given the fact that the person will have contributed for, I would say, less than about five years or so. It will depend on the age they retire and whether they want to delay their retirement and so forth.
For someone who is 64 years old who is retiring next year, it's a different situation. This is a person who will qualify for CPP, the normal age being 65, in their next year. So the CPP enhancement will be for younger generations. For that person, however, when you think of the total support that's being provided by the government, you have to look at it through the lens of the OAS, the move of OAS from 67 years to 65 years, the GIS support and top-up, depending on the income that the senior will be generating, and the broader package of middle-income tax cuts and so forth and where they stand there.
Often, for those who are 55 years or 64 years, you look at the support structure that exists now. There is a certain benefit that someone at 55 will get from the enhancement, but really it's about younger generations.
:
No, I think it has to do with the focus of the enhancement. The view of the CPP enhancement is not...and perhaps it's the reason why I'm having difficulty with your line of questioning.
From a Canadian standpoint, you're still going to benefit from a host of measures under the CPP core. I think as Marianna had outlined, there is a host of benefits there. The focus of the enhancement has very much been on income replacement. I hate having to keep coming back to this, but that is really the objective of this enhancement, to increase the income security of retiring Canadians going forward.
Marianna had mentioned some statistics just on the child-rearing side. Keeping in mind that this enhancement takes place over many years, if there is a view down the path, through these triennial reviews, that there have to be changes made to take into account issues, then that's the time to look at these issues through those triennial reviews. We will keep stock of these issues and the calibration that we have with respect to the enhancement and the base CPP as it goes forward. But for the purpose of the decision taken in June, the focus was on the income replacement side.