Pre-Transfer Repayment Policy

Purpose

The purpose of this Information Bulletin is to inform Registered Education Savings Plan (RESP) promoters of the Pre-transfer Repayment Policy.

The Pre-Transfer Repayment Policy is intended to clarify the repayment requirements in instances of an ineligible transfer.

Background

The obligations governing transfers from one RESP to another require that all of the incentives including the Canada Education Savings Grant (CESG) and the incentives paid under a designated provincial program be transferred proportionately. The proportional transfer rule prevents any incentive, other than the Canada Learning Bond (CLB), from being “left behind”.

If one or more of the incentives cannot be transferred, the transfer is considered ineligible and all of the incentives in the relinquishing RESP must be repaid prior to the transfer.

Repayment of ineligible incentives

Promoters may repay any incentive(s) including the CESG and incentives paid from designated provincial programs administered by Employment and Social Development Canada (ESDC), prior to a transfer, which would otherwise cause the transfer to be ineligible.

If the ineligible incentive is the Additional CESG and the receiving promoter does not accept to administer the Additional CESG (A-B Transfer Policy), then entire balance of the Basic CESG and the Additional CESG must be repaid.

For clarity, the balance of the incentive(s) administered by ESDC that make(s) the transfer ineligible must be repaid in full, regardless of whether it is a full or partial transfer. The earnings on the repaid incentive(s) remain in the plan and must be transferred proportionately.

Pre-transfer repayment process

Prior to processing the transfer, the relinquishing promoter will:

• Confirm the transfer eligibility information provided by the receiving promoter.
• Repay the incentive(s) administered by ESDC, which would otherwise cause a transfer to be ineligible.
• Report the repayment of the ineligible incentive administered by ESDC using repayment reason: “Ineligible Transfer”.

Continue with the transfer of the remaining assets in the RESP, in keeping with the established transfer process.

Impact on A-B transfer policy

The A-B Transfer Policy allows a receiving promoter, which does not offer the Additional CESG, to accept a transfer including Additional CESG providing that the receiving promoter agrees to administer the Additional CESG sibling only rule and report the presence of the Additional CESG in subsequent transfers. If the receiving promoter does not accept these conditions, the full balance of the Basic CESG and the Additional CESG must be repaid.

Pending grant

Following the transfer, any ineligible pending grant received must be repaid and any eligible incentive must be transferred to the receiving promoter.

Effective date

The Pre-Transfer Repayment Policy comes into effect as of October 1, 2015.

Contact Us

If you have any questions on this Information Bulletin, please contact us by e-mail at cesp-pcee@hrsdc-rhdcc.gc.ca or call at 1-888-276-3624. Our hours of operation are from 8 am to 5 pm Eastern Standard Time.

Annex A – Pre-transfer repayment process