Newsletter no. 04-2R, Registered Pension Plan Applications - Processing an Incomplete Application

October 11, 2013

This newsletter cancels and replaces Newsletter 04-2, dated April 30, 2004.

Since April 30, 2004, the Registered Plans Directorate no longer accepts incomplete applications for registering pension plans. Incomplete applications will be returned to the submitter, and for purposes of paragraph 147.1(2)(c) of the Income Tax Act, an application for registration will not have been made. By rejecting incomplete applications, we will be able to better serve our clients by focusing our resources on those applications that are complete.

Under paragraph 147.1(2)(c) of the Act, for a plan that is submitted for registration after 1991, the registration is effective from the later of: January 1 of the calendar year in which application for registration is made in the prescribed manner, and the day the plan began.

Under subsection 8512(1) of the Income Tax Regulations, the following documents must be sent to the Canada Revenue Agency (CRA) for the application to be considered complete:

1. an application form (the prescribed form is Form T510, Application to Register a Pension Plan, signed by the plan administrator);
2. certified copies of the plan text;
3. certified copies of the funding documents ^{Footnote 1} ;
4. certified copies of any agreements relating to the plan; and
5. certified copies of all resolutions and by-laws relating to the plan.

An acceptable certified copy could be either a signed original document, or a copy that contains an original signature or initials from the plan administrator, or the company seal, certifying that the document is a true copy of the original. If there is a board resolution that authorizes the establishment of the plan, a certified copy of the resolution must be submitted. If there is no board resolution, it must be clear that the administrator has authorized the application for registration.

Since May 2, 2005, we are accepting photocopies of signed documents listed above submitted when applying to register a pension plan as well as for the purpose of filing an amendment to a registered pension plan as required in paragraph 147.1(4)(a) of the Act and subsections 8512(2) and (3) of the Regulations. Similarly, photocopies of signed actuarial valuation reports will be permitted for the purpose of funding requests under the Act. If you submit photocopies, you must make the documents with original signatures available to the CRA when asked.

If the plan is based on an approved specimen plan, some of the documents that must be submitted with the application might be different from the documents listed above. For more information about requirements for specimen pension plans, see Registered Plans Directorate Newsletter No. 95-6R, Specimen Pension Plans - Speeding up the Process .

Applications that contain all the required documents will be deemed registered within 60 days. The application for registration will then be reviewed to ensure that the plan text complies with prescribed conditions and requirements of the Act. Our standard for responding to a complete application for registration is 180 days from the submission date. Our goal is to meet this standard 85% of the time.

The application for registration of the plan should be submitted to the CRA at the same time that the application for registration is submitted to the provincial or federal pension regulators.

Where to get help

Registered Plans Directorate

You can find more information at Savings and pension plan administration.

By telephone

Toll-free in Canada and the United States: 1-800-267-3100.

If you are calling from outside of Canada or the United States, call us collect at 613-221-3105. The Registered Plans Directorate accepts collect calls.

By mail and courier

Due to a building refit spanning multiple years, the Registered Plans Directorate’s mailing address has been temporarily changed. Please use the following address for all correspondence until further notice:

Registered Plans Directorate
Canada Revenue Agency
2215 Gladwin Cres
Ottawa ON  K1B 4K9

We welcome feedback on this bulletin. Send comments by email to RPD.LPRA2@cra-arc.gc.ca.