Over the past ten years, a large number of Canadians have accumulated significant sums in education savings, thanks to generous government incentives and widespread availability of RESPs. Financial institutions and group scholarship providers have been instrumental to this success. Our review of industry practices confirmed that, for the most part, the industry is delivering government programs in accordance with policy objectives and is encouraging and supporting Canadians who save for the education of children. We make some modest recommendations that may lead to even better results.
As we do so, we are conscious of the fact that industry standards and the government’s education saving policy continue to evolve. Providers may not always be completely in step with the changing environment. We advocate certain standards we consider appropriate but which at this time do not formally apply to members of the industry. As well, providers have made commitments to consumers who opened RESPs, and cannot change those existing plans freely.
Through our interviews with RESP providers we have found that financial institutions, including banks, credit unions, investment and securities dealers, are not actively promoting RESPs. We believe that this is less than fully conducive to achievement of the government’s education saving objectives. More Canadians would save for education, benefit from the grant, and be more fully aware of the range of RESP options available to them if financial institutions would take a more proactive approach.
Saving for education through RESPs is one of many saving options available to consumers. It is vital that consumers have good information that enables them to make choices that are in their best interest. Consumers would benefit from simple, clear information in plain language, a standard that group scholarship provider prospectuses could more closely achieve.
In addition to risks that flow from the type of investment chosen, savings in an RESP are also subject to the risk that the plan will not result in payment of all investment income, the grant and the bond to the beneficiary through EAPs. Various other outcomes are possible, depending on the type of plan. Consumers are made aware of these possible outcomes, but do not get clear, simple information about the probability that a plan will have a result other than the most desirable one.
The consumer who has a full appreciation of the risks and rewards attached to various RESPs can make good choices, not just among different RESPs and different providers, but also between RESPs and other forms of saving. Some might opt for other saving vehicles, including RRSPs and the new Tax-Free Saving Account, which have different risks and rewards.
We have shown that directors of foundations who are employees of the distributor or own shares in the distributor are in a conflict of interest, and that they make up the majority of two boards of the group scholarship trusts. We are concerned about this, as these organisations are entrusted with the delivery of major programs and play a fiduciary role towards both the government and the public.
Finally, we have shown that group scholarship plans produce desirable and less desirable outcomes in relation to the education savings policy objectives of the Government of Canada. On the one hand, group scholarship providers reach out to people who would otherwise not save for education and encourage many to save more than they otherwise would. Where the beneficiaries of these plans ultimately receive EAPs, the providers make a contribution to the government’s objectives.
However, they also impose a cost when plans are closed prematurely or when beneficiaries do not qualify for full EAPs and payment of the grant and the bond because of rules they, not the government, impose. Beneficiaries may be discouraged from pursuing post-secondary education for lack of financing. As well, subscribers to group scholarship plans that fail may also be discouraged from saving through other means.
Our concern is heightened by recent program data that show that lower-income Canadians disproportionately sign up for group scholarship plans, since they are more at risk of not being able to save according to a fixed schedule over a long term. Since the beginning of 2004, Canadians have opened nearly one million RESPs, and 76,000 of these drew the Canada Learning Bond. Nearly three hundred thousand of these RESPs were group scholarship plans, and 44,000 of these drew the CLB. The share of RESPs that attracted the CLB is three times as large among group scholarship plans as among individual and family plans.
We think that the government’s objectives would be better served if more RESPs in group scholarship plans survived until maturity and resulted in EAP payments, or if the consequences of other outcomes would be more favourable. Here are some potential changes that would move the plans in that direction:
A good way to proceed, we believe, is for the government to engage in consultations with all parties involved, including the RESP providers, to review the facts and develop new approaches.