Summary of Comments and Responses –
Consultation on Proposed Amendments Related to Public Statements
#
1.
Comment/Question
Defining the term “actuarial aspect” in proposed Bylaw 19.01.
Related questions:
• The scope is being broadened too greatly with the use of “an actuarial aspect”. This term can
be effectively argued to apply to almost any subject because actuaries are concerned with
health and finances. A great many discussion topics have aspects involving health and finance.
•
The use of “draw inferences” and “express opinions and advocate” can be used to promote
idealistic agendas when combined with the prior broadening, even when you add “consistent
with the Institute’s . . . values”. Our values can be espoused by any political agenda—even
ones that are not in line with popular Western thinking.
•
The removal of “opinion which . . . is primarily actuarial” allows our reputation to be tainted,
possibly politically, by the personal biases of the author.
•
I have a comment that could be oversimplified. How to define <actuarial aspect>? This term is
very broad and touches upon several areas. Do we need to establish a definition?
Do we want to target certain contexts for intervention? For example, the impact of marijuana
legalization on different risks in society and how institutions will have to consider the risk
transfer ($) to taxpayers?
In this context, should the CIA have a position for the consumer, the government, public
security, etc.?
•
The actuarial aspects should be dominant not only an excuse to express an opinion on nonactuarial issues.
•
A major difficulty is the lack of a definition of what is “actuarial”. Is it what is covered by the
syllabus? Or anything written by an actuary?
•
There should be a distinction made between statements that can be proven on the basis of
sound actuarial principles and statements that are probably true based on professional
judgment or experience.
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Document 217010
Response
The Governance Committee had modified the
wording in Bylaw 19.01 to provide more clarity
around this concept and which addresses the
issues raised.
2.
Issuing public statements that “have a significant element that goes beyond actuarial
considerations” or that take a position on an issue.
Related questions:
• Our existing bylaw is sufficient in that it provides for the CIA to issue public pronouncements
on matters within the competence of actuaries, where the subject has an important actuarial
element and such public opinion is primarily actuarial in its content.
o
Our only Guiding Principle regarding participating in public policy is: “The Institute
cooperates with governments and public bodies and makes timely and relevant
contributions to public policy issues.” There is nothing in here indicating that we need
to go substantially beyond the realm of actuarial considerations in order to provide
such contribution.
o
Our only strategic objective and goal in our current strategic plan is “Over the course
of the next five years, the CIA will be increasingly recognized as a valued contributor
to public policy debates pertaining to future financial contingencies and risks.” Once
again, there is no justification as to why we need to go beyond “actuarial
considerations”.
•
We should be using our scarce actuarial resources to better contribute to public policy where
there is an important actuarial element, not expanding public pronouncements beyond
actuarial considerations.
•
The CIA should be using the proposed changes to the policy (with suitable modification as
discussed later) to ensure the policy works prior to considering an expansion of issuing
actuarial public pronouncements beyond topics that have an important actuarial element. Fix
the policy first—and then manage and assess the improved policy to ensure it works, before
considering expanding the mandate beyond actuarial considerations.
•
Generally I feel that the CIA should stand up and be counted on areas of public concern
particularly those with strong actuarial connections. I do not feel that the CIA necessarily
needs to take a position but rather might publish statements showing the public the
advantages and disadvantages of different situations (for instance the pros and cons of
defined benefit pension plans versus defined contribution pension plans).
•
In starting this process, the Board recognized that a number of members have reservations
regarding the current process for CIA public statements. It is my view that the key areas for
improvement are to limit the CIA’s public positions to areas that are predominantly actuarial
in nature and to increase the level of member involvement in advance of a public position
2
Based on input received from the impression
audit conducted in 2015 and the results of the
member survey in 2015, the Board has agreed
to issue public statements according to the
criteria and process laid out in the Bylaws and
in the Policy on the Approval of Public
Statements, which include elements that may
go “beyond actuarial considerations” and/or
present a position or recommendation on a
given topic. The Board is confident that the
process established will ensure member
consultation and Board oversight, where
appropriate.
It is also the Board’s opinion that in order to be
“increasingly recognized as a valued
contributor to public policy debates pertaining
to future financial contingencies and risks”, that
the approach to developing public statements
that is being proposed is appropriate.
being issued.
While I am encouraged that there will be greater member input in the revised process, the
notion that the CIA explicitly intends to take public positions in areas that are not
predominantly actuarial is difficult to understand. I could find no rationale for this expansion
in scope in the supporting material. Importantly, the move to an advocacy model poses a
significant risk to the CIA’s standing as a professional body.
As a result, I do not support the revisions that are being proposed.
In their place, I would ask the Board to consider returning to the model that was prevalent in
the 1980s where the CIA would, in its public statements, in areas of clear actuarial expertise,
outline the pros and cons of various options without advocating for any particular outcome.
•
The evidence of recent "public statements" is that the executives of the CIA are not restrained
enough from making unsupported and often dangerous public statements.
Loosening those restraints is opening a Pandora's box leading to the complete destruction of
our Institute and profession.
Restraints should be tightened, not loosened and, in fact, all public statements should be
considered statements of actuarial opinion and subject, in full, to our professional standards
by each of the authors and promulgators, severally.
The public believes that public statements from the "Head Office" have the general support of
the membership and are within our professional competence. That belief demands humility,
rigour and discretion on our part. These qualities have been sorely missing for quite a long
time.
I hope you will publicize all comments received before moving forward and permit further
responses. Nothing affects our image as much as public statements. Appearing biased (recent
CPP comments), ignorant (the "leaky pipes" article on the landing page), or just lost in space
detract from our image.
•
It is said that the public statements may have a substantial element that goes beyond
actuarial considerations. The Board should understand and expect that this opens the door
for actuaries who disagree with statement content to do so publicly. They are no longer
dealing with technical issues but matters of opinion and, frankly, a disagreement with the CIA
will likely draw more press than whatever the CIA said in the first place. Public disagreements
between the Institute and its members will do nothing to enhance the reputation of the
Institute. It also highlights the danger of developing advocacy positions that do not flow
3
directly from a specified and limited strategic plan issue.
•
Such public statements should only be of a political nature following approval by the CIA
membership.
•
While I’m specifically against the CIA providing advocacy statements that extend beyond
specific actuarial matters, I realize that practically speaking, it is often difficult to draw the line
on when statements could cross this line over the continuum of possible statements.
I applaud the TF [task force] for developing a more thoughtful process. I think it should first be
applied with the current public pronouncements, that to my reading, are supposed to be
somewhat more limited in scope, but could use the additional member input and research
process outlined.
I’m particularly concerned with the stated goal that there may be opportunities for these
“level 2” positions every year, with 1 or 2 selected EACH year. It would seem to me that key
policy decisions that require research and the lengthy deliberative process would not occur
that frequently. If the intent of the statement was that only 1–2 would be worked on each
year (with some statements perhaps taking a few years to develop), then I think this is more
realistic. Otherwise, I think that the CIA will be issuing statements that extend to many nonactuarial related topics/nuances.
As currently written, I believe that the proposed changes to the Bylaws, section 19 are too
vague and provide much greater latitude in providing statements than I’m comfortable with,
and would vote against the current proposed changes.
•
In areas where the public statement is not limited to statements of fact, I believe it should be
made clear within the statement that the comments are opinions.
•
I do not believe our profession needs public position statements in their current form and I do
not agree with the proposed policy. The proposed policy changes allow for a clear pathway
for a position to be made public (whether actuarial or non-actuarial in nature) without the
consent or review by a majority of the CIA membership. This is dangerous in my opinion and
in the opinion of many other members because it has the distinct risk of giving the impression
of collective wisdom (of a highly prized and reputable profession) and the blessing of the
profession in general. But the process that the policy has outlined indicates that the pathway
to create a public position statement might only involve at most a dozen actuaries. The risk of
groupthink among any 12 individuals is very high and it is not a bet that I would recommend
to our profession on its reputation.
I personally witnessed the process of approving the genetic testing public position. I was one
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of a number of MSC members who assessed the research behind that public position and
several of us still believe that the research was NOT sufficiently strong to arrive at its
conclusions and it was certainly not strong enough to make the outlandish extrapolations that
led to the public position. To maintain the strength of our profession, we need a policy that
upholds the risk review principles that have made our profession the envy of many. At the
MSC, I voted against the genetic testing public positions and the research. I confronted the
research author and I pointed out the many flaws in his work. I was also contacted directly by
politicians who somehow became aware of my review.
•
•
3.
I do not support the current proposed policy change on public positions. In fact, I do not
believe we need CIA profession endorsed public position statements. I believe our profession
is strong. I believe our designation is strong.
An embargo should apply during an electoral period.
Why is the Executive Director listed as a person with whom the President should consult when
deciding whether or not to seek member input during the development of a public statement? He
is not an actuary.
Related questions:
• What does "in consultation with the Executive Director . . . and chair" mean? What is
consultation? Do the Executive Director and chair have veto power? I wouldn't think so but
putting this in the bylaw seems strange. It implies more power to these two individuals, than
just getting an opinion since it would be in the bylaws. I would suggest leaving it out of the
bylaws and putting it in some operation manual with more detail about what consultation
means if that word is used.
•
Why is the absolutely critical role here of determining whether or not a public statement has
"a substantial element that goes beyond actuarial considerations" being in part formally
delegated under the bylaws to the Executive Director, who is not an actuary—is this what the
members want?
•
The Executive Director is not an actuary and not otherwise subject to the Bylaws. Unless it is
proposed that this staff function be fulfilled by an actuary, the reference should be removed.
•
I do not agree with the Executive Director having any consultation role with respect to CIA
public statements. I do not have a problem with the President consulting the chair of the
committee responsible for the development of public statements as well as the chair of the
CIA committee to which the public statement applies.
5
The Executive Director and the chair of the
committee responsible for the development of
public statements were originally included in
Bylaw 19.02 (2) in order to provide members
with the context in which the President would
make his/her decision, and the reassurance
that the decision would be thoroughly vetted.
These two individuals are deeply involved in
the public statement process and could provide
excellent counsel to the President.
However, the Governance Committee has
streamlined the bylaw wording and removed
the reference to the Executive Director and the
chair of the committee, since the criteria for
making such a decision are included in the
Policy on the Approval of Public Statements,
and it was also felt that the President would
naturally consult these individuals and other
subject matter experts as well, in making the
decision.
4.
5.
Calling a special General Meeting in February to get member confirmation of the amendments,
instead of waiting until the scheduled Annual General Meeting in June, as would be the normal
process.
Related questions:
• In recent years, there have been a number of proposed bylaw changes, which, in the normal
course of things, were voted on at the Annual General Meeting in May/June. What is so
special about these particular proposed bylaw changes that the CIA feels it is necessary to
instead call a special General Meeting in February or March (when most appointed actuaries
are very busy), instead of waiting until the scheduled Annual General Meeting in June, as
would be the normal process?
• “. . . a General Meeting would be convened. . .” – is that absolutely necessary? Wouldn’t a
vote by proxy/online be sufficient?
Voicing the views of dissenting members.
Related questions:
• What will prevent the CIA appointing a majority of task force members from the ranks of
those who are known to support the point of view preferred by the powers that be?
•
Presumably the task force “champion” will be named from among the most ardent supporters
of the point of view preferred by the powers that be
•
In drafting level 2 public statements, what heed will be paid by the task force and the Board
to the views of dissenting task force members? To the input of members who do not support
the point of view preferred by the powers that be?
•
There should be transparency where there are contrary views. I don't think that we must
strive to have unanimous statements and we should recognize that there are many topics
where there are strong opinions that differ.
•
“. . . the benefit of the full range of the profession's capabilities” . . . should mean that
minority opinions also be communicated when there is a significant proportion of the
members that have expressed a dissenting opinion. That could mean say 15 percent. Pros and
cons or alternative policy options can have value added in a political process: the best can be
the enemy of the good!
6
Despite the lengthy delay that will follow the
adoption of the Bylaw amendments by the
Board if no special General Meeting is called in
February, the Board has decided to wait until
June 2017 to seek member confirmation of the
amendments through the routine process.
The spirit of this process, and in fact, of all of
the Institute’s initiatives, is to ensure
appropriate representation of our members’
viewpoints on our volunteer groups, wherever
possible. It is common practice to seek out
members with differing viewpoints on issues,
when recruiting for a committee or task force.
The Blue Ribbon Task Force on Public Policy
was a shining example of that (members were
recruited because they had differing views),
and the end-product of its work was something
that was supported by all of its members.
The Governance Committee did not choose to
include a requirement to voice dissenting views
in relevant reports; however, the drafting
entity could do so if it was deemed appropriate
based on the specific circumstances.
6.
I've briefly looked at proposed 19.01 and 19.02 and it would seem there is a possibility of conflict,
since it is possible that the Board believes a pronouncement should go to the membership and
the President doesn't or vice versa. It’s not clear how this gets resolved. Also when does it go to
the Board versus the President?
7.
My main reason for writing is to urge the CIA to consider the readers of their public statements
and whether they are effectively getting through to them. Too, too, often the CIA public
statements that I have read are like actuarial treatises written for a university course. If we want
to get through to legislators and opinion makers who are stressed and time constrained then the
writers of CIA public statements should first think about the main message they want to transmit
and how they can quickly—very quickly—get their reader's interest. This is a skillful job and not to
be undertaken without much thought. CIA members seem to want public statements to dot every
"i" and cross every "t" whereas they should realise that the principal concern is to transmit a
message and if that is done successfully then filling in all the detail and giving a more complete
picture may come later when the reader has been aroused to want to know more. So a forceful
headline/opening statement/executive résumé followed later by a longer dissertation may be the
general format to be adopted for CIA public statements in future. Remember that the message is
only effective if it is read.
The following questions are not actionable in terms of the proposed bylaw amendments and
policy:
• Given that it was appointed effective February 1, 2016, why did the CIA wait until September
1, 2016 to reveal the names of the committee members, other than the chair, via the
September (e)Bulletin?
8.
•
Bylaw 19.02 (1) allows for the Board to
establish the “terms and conditions” under
which a public statement would be developed.
The Policy on the Approval of Public
Statements serves as these “terms and
conditions” and provides the necessary clarity
regarding the process that is to be followed.
Comments have been noted and will be passed
on to the appropriate entity for future
consideration.
Comments have been noted and will be passed
on to the appropriate entity for future
consideration.
Given that it consists mostly of insider old boys/girls who mostly are current or past Board
members, how can it be considered to be independent and non-partisan, like a blue ribbon
group should be?
Given that a later created task force re: CPD is listed, why is this task force not listed on the
CIA website under Board task forces?
Any required research will be managed by the Research Committee—will this process work like it
did re: genetic testing, where, for instance, the January 2016 report to the Research Committee
which was issued to further support the June 2014 public statement on genetic testing and
insurance (see related bullet below) did not even follow current requirements for research
papers, and where it appears likely that the work was both supervised and peer reviewed by the
same persons, perhaps all of whom shared the preferred point of view by the powers that be (i.e.,
•
9.
7
The process surrounding the development of
research reports is ever-improving and will
follow the same spirit and intent noted in #7
above. Everyone involved in the CIA’s initiatives
is well-intentioned and seeks to do the very
best job that they can while protecting the
that Bill S-201 is contrary to the public interest - see link below)?
https://openparliament.ca/bills/42-1/S-201/
10. It seems to me that there are two main questions which the members need to think about:
•
Are the proposed bylaw amendments and their stated purpose in the public interest?
•
Are the proposed bylaw amendments necessary to achieve their stated purpose?
The July 14, 2014 communiqué (see link below) and accompanying June 2014 public statement on
genetic testing and insurance, which amongst other things stated that “sharing known results of
relevant genetic testing is in the public interest”, was developed and released under the current
versions of bylaws 19.01 and 19.02. Surely this is an example of a public position “where the
issues have a substantial element that goes beyond actuarial considerations” (i.e., one which
would belong in the new level 2 category)—if this public statement, which was clearly partisan
and a fine example of spin doctoring and advocacy bordering on lobbying by the CIA, could be
released with impunity under what we are now calling level 1, why are any changes to bylaws
19.01 and 19.02 necessary?
http://www.cia-ica.ca/publications/publication-details/214085
11. Member consultation is desirable whenever feasible (even Level 1 statements).
Related questions:
• As proposed, the Bylaw would not require member input on public statements unless the
Board (or President) determines that the issue has a substantial element that goes beyond
actuarial considerations. In other words, there is no automatic requirement for member
input, only an exception. At a minimum, the onus for this requirement needs to be reversed.
The revised bylaw should require all public statements to have member input and Board
approval, with only an explicit exception avoiding this requirement. The exception would only
be provided if the Board (or President) determines that the issue does not have a substantial
element that goes beyond actuarial considerations.
•
Even if the Board (or President) determines that the issue does not have a substantial
element going beyond actuarial considerations, the default should require that members
have an opportunity to provide input (unless a specific exemption for such member input is
provided by the Board (or President)), and only for issues regarding time constraints or
confidentiality.
•
Member input should be facilitated for all level 1 public statements (i.e., where issues that do
not go beyond actuarial considerations) with the exceptions being only for time constraints or
confidentiality.
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public interest and supporting the Institute.
Under the new Bylaws and policy, it is likely
that such a report (genetic testing) would be
categorized as a level 2 public statement. Such
an option did not exist when the genetic testing
paper was released, and it was therefore
developed under the interpretation of the
current versions of 19.01 and 19.02 and the
existing Policy on the Approval of Public
Positions.
The nature of a level 1 statement is that it is
based on existing CIA material (e.g., standards,
guidance, research, public statements) and
would not require further member
consultation. Often, time is of the essence is
preparing a response to a request from an
external party.
The current proposal sets out what the Board
feels is the best way to manage the member
consultation process.
•
When level 1 public statement are being contemplated, the topic (and brief summary) should
be announced to the membership so that the membership can express an interest in
participating in the drafting committee, or at least submit their thoughts on the subject to the
drafting committee (with the only exception being confidentiality).
•
Hopefully, a summary of the issue justifying the preparation of a public position is prepared
prior to expending volunteer resources in preparing it. Since the topic is primarily actuarial,
what justification is there for not releasing the topic to the membership other than
confidentiality?
•
The policy should require a draft of level 1 public positions be released to the members prior
to public release of the final document, with the only exceptions being time constrains or
confidentiality. If not, why not?
•
The proposed policy requires a summary of input from members and other interested parties
prepared and sent to the Public Statements Committee. This should be changed such that this
is also released to the membership.
12. The member consultation process itself.
Related questions:
• Re: Level 2 public statements, this new proposed clause says in part that “where the
public statement is considered, by the Board or alternatively, by the President, in
consultation with the Executive Director and the chair of the committee responsible for
the development of public statements, to have a substantial element that goes beyond
actuarial considerations, the process will include member input and Board ratification”.
The member input contemplated here appears to have no teeth—is this what the
members want?
•
What if a significant number of members might believe that a public statement which the
CIA categorizes as level 1 is really level 2—do members trust the CIA powers that be to
make these decisions for them?
•
As written, it only provides for member input to be obtained, but imposes no
requirement that it be used or reflected.
•
A public position on behalf of the members should require consensus or in the absence of
consensus, provide the alternative views presented by the members. Our public would
expect that a public statement issued by the profession on behalf of the members would
have consensus support by its members. If we issue it without such member support, as a
profession we are being dishonest. Even in cases where there is consensus, but still a
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Member consultation is exactly that—
consultation. It does not mean that we will be
able to achieve consensus on a given topic.
Ultimately, it is up to the Board members who
have been duly elected by the members to
make decisions on behalf of all of the members.
A thorough due process surrounding the
development of a public statement is meant to
ensure that appropriate decisions are made
that would be supported by the majority of
members.
significant minority alternative view, such alternative view should be acknowledged and
discussed in the public statement.
•
Who is in charge of choosing our position on delicate topics? Will there be a mechanism
for consulting members?
•
Use the CIA general lists/communication/announcement channels to get fast input from
members. Don’t just use the Member Listening Group (MLG). You can put a two-day or
five-day turnaround if it is needed quickly. It might be helpful to build that in to any policy
developed.
•
If there is some urgency with respect to obtaining member input, then the member input
period could be shortened appropriately.
13. Staffing of the drafting entities.
Related questions:
• Individuals involved in the drafting committee should be precluded from being part of the
authorizing committee. This is a problem and is encouraged under our current policy. It
should explicitly be prohibited.
•
The Governance Committee considered these
comments but no changes were made to the
proposal in their regard.
I also believe that the membership at large should be given the opportunity to volunteer to be
on the drafting committee; those not selected for the drafting committee should at least be
given one chance to comment on any public position and have their voices heard.
•
I see that having smaller groups of people provide the public statement should facilitate
timely statements. Where a few people have provided input to the public statement, those
people should be identified. The statement should outline the qualifications of those people
for providing such a statement. This is not to set them up for challenge but to highlight how
their experience contributes to the statement.
14. It is critical that public positions are reviewed for any possibility of conflict of interest or when our
profession appears to be co-opted for championing someone else’s battle. Once again, our policy
should clearly state the need for an independent external party opinion on this issue of the
“independence” of the research and the position itself.
15. The approval of a public position statement should consider whether there is any significant
difference to publishing the very same statement or finding under the pen of its authors only (not
on behalf of the profession, but simply the authors as FCIA’s). Again this consideration should be
reviewed and opined on by an EXTERNAL party because impartiality is critical. The reason to do so
again should be to ensure that positions that are truly substantive and groundbreaking for the
profession and the public are held to be public positions for the profession. I believe the weight of
the individual authors as qualified FCIAs is sufficient in many cases and certainly will carry
10
The Governance Committee considered this
comment but no changes were made to the
proposal in its regard.
The Governance Committee considered this
comment but no changes were made to the
proposal in its regard.
16.
17.
18.
19.
significant weight for Joe Public.
All public positions must be supported by a formal actuarial research undertaking; such research
should be one that members of the CIA were the primary contributors [to] and that their
expertise and skills were applied appropriately (using best practice or applicable standards) to
uncover something new and insightful. Where other professionals are required, these should be
noted and included in the write-up. All research topics should be made aware to the membership
and all the research findings/working papers/conclusions should also be made available to the
membership before its public position is published.
All public positions that do not have the opportunity to be shared with the entire membership for
a vote must at the very least obtain UNANIMOUS approval by the CIA Board of Directors (in other
words, if a public position is so critical, then the elected representatives of its membership should
support it strongly). Unanimous or super majority is a critical criterion for the approval because of
the reputational risk of public positions. Imagine that the Board vote is “split” or marginally in
favour, then it is very likely that the membership in totality will also be polarized on the topic. To
publish a position that is polarizing does not make our profession stronger. Our goal should be to
make public only the positions that are the most substantial and truly ground-breaking for the
profession and the public that we serve. I believe we would all want that. The fact that we are
churning out dozens of public statements per year is also an indicator that something is wrong
with the current/proposed policy.
All public positions must prove that their conjecture or proposed policy are in fact in the public’s
best interest—this proof of the public’s interest must be reviewed and agreed [on] by a suitable
party that is EXTERNAL to the actuarial profession. The public’s interest is something that is often
a debatable matter, and it is important to ensure that there is impartiality on asserting this
judgment.
Acronym for committee of approving public positions should not be PSC. This conflicts with the
Practice Standards Council.
20. If a level 2 public position is being drafted (meaning that it goes well beyond actuarial issues), why
is it desirable that drafters be from the practice area (which should only reflect actuarial issues)?
21. It is poor drafting to have a formal policy to simply state something is desirable. This has no teeth.
It is either a requirement or it isn’t. It goes on to waive this requirement—but there is no
requirement to waive—it is only a desire.
11
The proposed process does include the option
for research to be conducted prior to issuing a
level 2 statement.
The Governance Committee considered these
comments but no changes were made to the
proposal in their regard.
The Governance Committee considered this
comment but no changes were made to the
proposal in its regard.
The Governance Committee considered this
comment but no changes were made to the
proposal in its regard.
The Practice Standards Council (formerly the
PSC) no longer exists. In 2006, it was split into
the Actuarial Standards Board (ASB) and the
Practice Council (PC).
Most topics will likely still be related to a
particular practice area and it would be
desirable to recruit drafters who are
knowledgeable in that area, whenever possible.
Our policies are often designed to help provide
guidance to the users of the policy, in addition
to the strict “rules” and “guidelines” that are
normally found in policies.
22. If there is a report to be prepared by the drafting committee, this should also be made available
to the members before issuing the public statement.
23. What report by the drafting committee is contemplated in 2d and 4b? There is no section
indicating that the drafting committee is preparing a report.
24. There are major sections in the proposed policy called “Context and Purpose”, “Scope” and
“Policy Statements”. What are policy statements?
25. The October 2016 (e)Bulletin notes that the Board recently approved five potential public
statement topics for further investigation—exactly what are these five topics, and which, if any,
would fall into the new level 2 category, and why?
26. The wording of 19.02 (2) is very difficult to read and interpret. It implicitly refers to level 2 but
remain ambiguous as to level 1. It would be better to include there directly the definition of levels
1 and 2.
12
The Governance Committee considered this
comment but no changes were made to the
proposal in its regard.
Item 2d is referring to the “cover memo”
prepared under 2b. The terminology has been
changed to be consistent.
The comment related to 4b is unclear since
there is no reference to a report in section 4.
Policy statements are meant to elaborate the
details surrounding the specific rules,
guidelines, restrictions, etc. that one needs to
follow with regard to the work that is to be
performed pursuant to the policy.
It has not yet been decided which topics
discussed by the Board will be pursued with
regard to developing a public statement. It
would therefore be premature to release them.
Additional information has been requested and
the Board will consider the topics in due
course.
Under the revised proposal, however, all topics
that are identified proactively (i.e., the Board
chooses to develop a public statement on the
topic vs. the CIA being asked to respond on a
topic) will automatically be designated a level 2
public statement, with member input and
Board ratification being sought. This was a
change that was added to the revised version
of the proposed amendments following the
consultation period.
Bylaw 19.02 (2) has been revised for better
clarity and level 1 and level 2 have now been
defined in the policy.
27. I believe that if our home [head] office provided support to individual members to make their
hard work and insightful research more visible then the public at large would gladly take notice of
content or commentary written under a member’s own pen. Many of our members are already
doing so and we can help others to do the same. We would achieve the very same result that you
are trying to achieve in the public domain because people respect our designation and our
people.
28. Public pronouncement versus public statement versus public position
• The existing bylaw is with respect to public pronouncements of opinion. As proposed in this
change, the bylaw is with respect to any public statements where the subject has an actuarial
aspect.
•
The existing policy is with respect to the approval of public positions. The proposed policy is
with respect to the approval of public statements.
•
This has a positive element of aligning both the bylaw and the policy to be with respect to
public statements (instead of one being “pronouncements” and the other being “positions”).
•
This also has the positive effect of clearly making “press releases” issued by the CIA “public
statements”, particularly [within] the context of what a public statement is as expressed in
the policy.
The comment has been noted and will be
passed on to the appropriate entity for future
consideration.
As noted in the Policy on the Approval of Public
Statements – Context and Scope:
“Communication tools (e.g., a press release, a
letter to the media, opening comments for an
appearance before a public committee, media
interview Q&As) consistent with approved
public statements will be prepared by the CIA’s
internal and external expert resources, and be
approved by the President.” This is consistent
with the previous Policy on the Approval of
Public Positions.
The Governance Committee considered these
Press releases are public statements, yet it does not appear that they are addressed in the
comments but no changes were made to the
Policy
proposal in their regard.
• Although the proposed wording eliminates what the CIA deems to be a loophole permitting it
to issue press releases in violation of the existing bylaw, the new Policy on Public Statements
(which is to cover all public statements issued by the CIA) does not appear to address the
process for approving press releases.
•
Hopefully this will be directly addressed with appropriate oversight so that we don’t have
press releases such as the following without at least getting member input or opportunity for
comment:
o
“Agreement on a CPP expansion will improve the future financial security of
Canadians,” said Robert H. Stapleford, President of the CIA. “This is a significant
achievement.”
o
“Canada’s actuaries support the decision by the federal government to restore the
mandatory long-form census questionnaire.”
o
“The federal, provincial, and territorial governments have a ‘once-in-a-generation
opportunity to ensure Canada’s retirement system meets the needs of current and
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future retirees,’ said Rob Stapleford, President of the Canadian Institute of Actuaries
(CIA), the national voice of the actuarial profession in Canada.”
•
Such statements are clearly public statements made on behalf of the profession, thus should
be governed by the policy.
How will changes capture public statements being made directly by committees or task forces?
•
Consider the following press release from June 2015 (not terribly controversial, but clearly a
public statement).
o
Target benefit pension plans (TBPs) are a viable alternative design that should be
made more readily available to Canada’s pension industry, the Canadian Institute of
Actuaries (CIA) said today.
•
This press release statement is based solely on a task force report. http://www.ciaica.ca/docs/default-source/2015/215043e.pdf
•
This is problematic because the task force report clearly states that “Committee and task
force reports represent the views of the committee or task force and do not necessarily
represent the views of the Canadian Institute of Actuaries” yet despite the disclaimer in the
report, the press release clearly elevates the report’s findings to being the position of the
CIA.
•
This is another reason that press releases must be captured under the public statement
rules. If the press release only announces that research has been prepared, it must be clear
that it is not necessarily the view of the profession. But if the press release indicates that the
CIA adopts the view presented in the research, then it must be governed as a public
statement.
•
It also raises a concern regarding what oversight, if any, will the Public Statements
Committee have (or should have, or shouldn’t have) over task forces and committees
performing research such as this.
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