• authored by news
  • published Sat, Jul 20, 2002

MFD Weekend: Figures don't lie but...

Integrity among those who manage money - especially large heaping piles of it - is finally a fit subject for discussion, even in polite company as one scandal after another is shaking the business community. Insider trading, conflict of interest, creative accounting - there seems to be no end to the rule bending that goes on in the name of being - or at least looking - profitable. To make matters worse, the guys who are supposed to help the biz guys regulate themselves - the accountants and auditors - are right in there with them.

We've had Enron and Arthur Andersen, Nortel Networks and Deloitte Touch, now Price Waterhouse is in the dog house, the list seems endless. Share prices are plummeting and public confidence in the good intentions of corporate wheeler-dealers is sinking like a rock. Even staunch defenders of the free market are sheepishly calling for regulation, transparency and accountability. Stateside, George Dubya has been wagging his finger at his corporate buddies (although he's not squeaky clean himself as it turns out) and here in Canada, the federal government announced the establishment of a Canadian Public Accountability Board - a new regulatory agency that will police auditors employed by Canadian publicly traded companies.

But it isn't just wealthy investors who need to be concerned and protected. Billions of dollars of working people's money is sitting in union pension funds where - supposedly - it is being invested prudently to generate the best possible return at minimal risk. Millions of workers will depend on those returns to provide them with a reasonable standard of living on their retirement. Few know much about their pension funds. While some union funds do very well and are clearly well managed, others most definitely are not.

It was about a year ago that we told you about the UFCW's $500,000 pension adventure with a defunct Internet service company called Webgalaxy. Since then, we've heard about the, the UA's $29 million dollar loss in an investment firm called Capital Consultants, the $800 million the UA (again) has sunk into a not-too-busy Florida resort, the $22 million the Edmonton Pipe Industry Pension Fund coughed up to by some golf courses, and let's not forget the ULLICO fiasco.

Then we have the Canadian Commercial Workers Industry Pension Fund - a massive jointly trusteed multi employer plan that involves some 400 different companies and their workers. CCWIPP and its intriguing - to be polite about it - network of investments in real estate and hotel industry have been the subject of considerable discussion on this web site (See Sins of the Father, Haunted Houses of Labour, Opportunity Knocks). Now we are not accusing anyone of impropriety. We're simply curious about the prudence of these investments and what kind of return they're generating for the workers. We're not the only ones who are curious either.

This worker from eastern Canada is a member of the UFCW and of the CCWIPP. He recently told his story in MFD forum. It seems that he's been trying to get some answers for some time now about what's happening to his pension plan. The answers have left him with more questions and more concerned than ever.

"About 6 years ago some of our members noticed that the rate of return for the amount of money that we were putting into the plan was getting smaller, so we went to the (Union) Business Agent and asked him. We were told we were trouble makers and if we didn't like the plan we should get out of it. So we decided to do our own research.

We sent a letter to Cliff Evans, a director and chief investment officer (of the CCWIPP). He replied that the Alberta Pension Commission was looking into the solvency of CCWIPP. I then wrote the Alberta Pension Commission and they stated that CCWIPP was having some funding problems and hopefully could work out these problems in a few months. We then received notice from CCWIPP stating that if you were not eligible to retire in 1997 or were not 50 years old in 1997 there would be a reduction in your pension if you retired at 60 of one-half % a month or 30% from age 60 to 65. When we got into CCWIPP we could retire at 60 with a full pension. CCWIPP also stated that for those who were not eligible to retire in 1997 there would be a supplement called the Supplementary Income Benefit (SIB) WHICH WOULD BE PAID TO PEOPLE WHO RETIRE AT 60 SO THEY WOULD NOT TAKE A 30% REDUCTION. It also stated that the supplement would be reviewed from year to year, available finances permitting.

We then received our 2000 statement from CCWIPP .The statement said that if you were not eligible to retire in 1997 you would take a reduction of 30% at age 60, 60% at age 55 and 90% at age 50. There was no mention of the SIB. Prior to receiving my statement I wrote (UFCW Canadian Director) Mike Fraser about the pension reductions. He called me and guaranteed that I would get my full pension at 60. When I received the statement I then wrote the Board of Directors asking them to guarantee me in writing that I would get my full pension at 60. Their reply was Alberta have now decided not to approve the payment of the SIB in the form which it has been currently structured. Therefore, the payment of the SIB has been suspended. Why were the members not told that the supplement had been suspended? Why was the Vice President of the local who works at our plant telling people that there would be no reduction in pension at age 60 when it simply was not true? The supplement was removed.

I received an email from the Alberta Pension Commission about the supplement. They said that CCWIPP currently has some funding problems. These were caused by a number of things, most notably some inaccurate information from one of their advisers (who I've been told has been fired).

The members then received a memorandum and a letter from the BA and CCWIPP stating that the SIB has been reinstated. NO ONE WAS TOLD IT HAD BEEN SUSPENDED. We were told the pension funds had been transferred from Alberta to Ontario where solvency requirements are less severe. A payment of 55 cents per hour would give you a pension of $40 per year now we need 65 cents per hour to get the same benefit.

I have written the Board of Directors asking these questions: Who was the person that was fired, what bad investment advice did he give the Trustees of CCWIPP? I asked for a full disclosure of investments that have contributed to the funding problems of CCWIPP, who recommended and approved those investments decisions and did any money from the fund go to businesses in which CCWIPP trustees have an interest. I asked for a list of companies and investments that CCWIPP is investing in. I also wanted a guarantee that I will get a full pension at 60. I sent a copy of the letter to (the Financial Services Commission of Ontario).

This pension reduction at age 60 and no guarantee of the supplement represents a direct financial threat to thousands of CCWIPP members in our age range who were planing to retire at 60 with some dignity. The pension statement says the Trustees have agreed to finance an additional monthly payment provided that the annual actuarial review confirms that funds are available. (That says it all).

According to my pension statement, if I were to retire at age 60 there is a 30 % reduction in my pension. I calculated my pension at 60 assuming the current rate of $40 per year to be $800 per month minus 30% or $240 which gives me $560 a month less taxes. I cannot figure in the supplement because it is not guaranteed from one year to the next. This huge pension is my reward for working 30 years in a meat plant. THANKS UFCW FOR THE FINANCIAL SECURITY."

Downeaster, is still waiting for answers from the CCWIPP and the FSCO. His story should be a wake-up call for union members who are concerned about the quality of life they will have on retirement.

What is the story? What degree of risk is acceptable for pension funds that are intended to provide a measure of security for workers who otherwise stand a good chance of retiring into poverty? How accountable are the Trustees of these funds to the members? What safeguards ought to be in place to guard against conflict of interest, inappropriate risk-taking and the kinds of disasters that are plaguing the business community? What role should the regulatory agencies like the FSCO play in the oversight of these funds?

Tell us what you think.

  • posted by lefkenny
  • Sat, Jul 20, 2002 11:29am

Hydro One chief fired 'with cause'
'There will be no termination or severance package'

Shannon Kari, The Ottawa Citizen
Saturday, July 20, 2002

TORONTO -- Eleanor Clitheroe, the controversial chief executive of Hydro One Inc., was fired yesterday by its new board of directors for personal expenses billed to the public utility.

The expenses included hundreds of limousine rides for her family and memberships to seven of Toronto's toniest private clubs.

"This was a corporate culture that believed any amount of expense was OK," Glen Wright, Hydro One's new chairman, said at a hastily called news conference.

Mr. Wright placed the blame squarely on Ms. Clitheroe, and the former board, which resigned last month after an investigation into executive pay at the provincial electricity distribution grid. "This has to do with the governance culture at this organization and not the employees who work here."

Ms. Clitheroe, 47, one of the most powerful female executives in the country, was formerly a managing director and chief financial officer at the company. She previously served as Ontario's deputy minister of finance and is the current chancellor of the University of Western Ontario.

The expenses included $330,000 in limousine charges billed to Hydro One by Ms. Clitheroe, who was already provided with an automobile allowance for a new car every 12 months, valued at $170,000, in addition to a standard car allowance.

Lots more here

It is one executive after another. One organization after another. While some people are willing to blow the whistle on actions that are suspect of corruption, other people especially in unions are not so willing to disclose any action that even remotely resembles corruption.

It is my political opinion that Members in unions are brainwashed to belive that it is disloyal to taddle on any union member or union action. It has become taboo to rat out on even the most outrageous union act of corruption. Yet there is no legislation with teeth in Canada that makes unions accountable to anyone.

Do we know anything that union leader-ceo's do or how they do it? How would we know? There is full disclosure of financial statements or laws demanding that unions disclose the financial statements to it members.

Union leaders with their cozy autocratic positions have very little to fear. With cult like loyalty, union leaders are free to practically do as they please. Even when someone does contest decisions made by union leaders, they are met with the normal legal response. Yes, a law suit intended to silence any scrutiny. This is the very case with Members for Democracy, who is being sued by United Food and Commercial Workers Union.

What will it take for union members to wake up and understand that there is no difference between human beings that run businesses or unions. Corruption is corruption regardless of where you find it. Union members will be far better off when unions are held accountable for their actions and the future of all its members.


  • posted by Duffbeer
  • Sat, Jul 20, 2002 3:00pm

I wonder how this will go down, another extension perhaps?

From AFM Press Release in The Haunted Houses of Labour :


* The Major Creditor [I.F. Propco Holdings (Ontario) 23 Ltd] will extend the principal repayment of a further $2,000,000.00 currently due the 31st of December, 2000 to the 31st day of July, 2002, and AFM will cause its wholly owned subsidiary, Northwest Lodging International (USA) Inc., to give security over all of its assets

I.F. Propco Holdings (Ontario) 23 Ltd., AFM's major creditor, is beneficially owned by the Canadian Commercial Workers Industry Pension Plan (CCWIPP) which, itself, currently holds 15.8% of the issued and outstanding common shares of AFM

Do I have this in order?

CCWIPP owns 15.8% of AFM
CCWIPP "beneficially" owns I.F. Propco Holdings
CCWIPP loans, through I.F. Propco, funds to AFM therefore:
CCWIPP is loaning money to itself.

Would all this be considered creative accounting?

  • posted by Downeaster
  • Sat, Jul 20, 2002 7:21pm

I wonder how much Bill Personwill get \when he retires at 60 . Could he tell us about his pension plan and how much he makes as a union president?/

  • posted by retailworker
  • Sat, Jul 20, 2002 7:37pm

i don't think he'll be back until sunday night. but union slaries are available at the DOL web site. bill's posted previously that he makes 80k

  • posted by Downeaster
  • Sat, Jul 20, 2002 7:56pm

If Bill MAKES 80.000 then he makes 50.000 more than me . What is his pension and who pays his his premions THE LOCAL OR HIMSELF. Downeaster

  • posted by weiser
  • Sat, Jul 20, 2002 8:10pm

Let's get back on Pensions. Why would CCWIPP invest $5 million in a troubled company that only has assets of only $635,355?


From: Kitchener/Waterloo Record

Bankrupt MGI owes creditors $12.7 million
Monday July 16, 2001

Ron DeRuyter


KITCHENER -- MGI Packers owes more than 600 creditors $12.7 million, according to bankruptcy documents.

The Kitchener company was pushed into bankruptcy in June, 19 months after it shut down its beef slaughtering and processing operations.

A meeting of creditors will be held tomorrow in Kitchener.

According to MGI's statement of affairs, the company owes three secured creditors $5.2 million.

Their claims are secured by pledges against the assets.

The secured creditors are I.F. Propco Holdings (Ontario) 49 Ltd. of Toronto ($5 million), Magda Mueller of Niagara Falls ($175,000) and GMAC Commercial Credit Corp. of Toronto ($18,600).


I.F. Propco is affiliated with the Canadian Commercial Workers Industry Pension Plan, the pension plan for members of the United Food and Commercial Workers union.

The union represented production employees at MGI.

MGI, a 14-year-old company that employed 350 people, has one preferred creditor -- the Receiver General for Canada -- owed $49,576.

Preferred creditors have unsecured claims which rank behind secured claims, but ahead of the claims of ordinary unsecured creditors.

MGI lists 621 unsecured creditors who are owed almost $7.5 million.

They include 351 cattle suppliers who provided MGI with livestock worth more than $2.8 million.

Most of them were compensated by the Livestock Financial Protection Board, a provincial agency that administers a compensation fund for sellers of beef cattle.

Their claims have been assigned to the board.

MGI's largest unsecured creditors are Mueller Meats and Maple Freezers.

Mueller Meats, a company owned by the Muller family, MGI's largest shareholder, is owed $703,459.

Maple Freezers, a Muller family business that owns the plant on Maple Avenue where MGI's beef was processed and kept in cold storage, appears twice on the list with claims of $691,065 and $894,200.

Kitchener's revenue division has a claim for $86,736.

MGI's former employees aren't listed as creditors.

However, they are owed severance pay, said Dan Onichuk, director of the United Food and Commercial Workers Local 175.


"They should be on the list. The amounts certainly are outstanding," Onichuk said.

MGI's statement of affairs lists assets of only $635,355.

They include machinery and equipment ($550,000), accounts receivable ($70,355) and inventory ($15,000).

MGI owned the equipment in its slaughterhouse on Arnold Street, but the property is owned by Continental Trading Co. Inc., another Muller family

Indusite Realty Corp. has been looking for buyers for the plants on Arnold Street and Maple Avenue, as well as the equipment, on behalf of Mintz &
Partners Ltd., MGI's receiver, and the other companies owned by the Muller family.

Thursday was the deadline for submitting offers.

David Moore of Indusite said it will take several weeks to review the offers.

"There are a number of situations on the go, but nothing has been decided," he said.

  • posted by Richard
  • Sat, Jul 20, 2002 8:40pm

Wow! I just had an evil thought….

What would happen if a union pension fund invested $100 million in a cornflakes factory and then the new owners ran the factory until it was bankrupt. Then when it was in bankruptcy, the pension plan accepts 10 cents on the dollar (from some dudes who just happen to be in the neighborhood) in an attempt to recoup its losses. The pension plan lends out $100 million for a previously profitable factory that is assessed at $100 million, but winds up losing $90 million.

Now the 'dudes' who just happened to be in the neighborhood and who just picked up a $100 million cornflakes factory for $10 million just happen to have a buyer who was begging to buy the cornflakes factory at $95 million, but for some reason the guys who borrowed the money from the pension fund weren't interested in selling at $95 million; they just sat around until they went bankrupt and the factory was sold out from under them for $10 million.

The mysterious 'dudes' flip the cornflakes factory to the guys who've been begging to buy for the $95 million, which makes them a nice, fat $85 million profit, and leaves the pension plan with a $90 million loss.

Hey, I just had an even more evil thought....

What if the "dudes" didn't just happen to be in the neighbourhood? What if they were friends of the union pension dudes and they were part of an evil plot to make money off of a the union pension plan?  -

Hey, what am I talking about? Stuff like that only happens in movies; right?

  • posted by retailworker
  • Sat, Jul 20, 2002 8:44pm

didn't i see that on The Sopranos?

  • posted by Richard
  • Sat, Jul 20, 2002 8:57pm

It's Sopranos type of material, but let's go further... (how much do they pay for TV scripts?)

What if some big employers hung out on the pension board and knew what was going on. And what if they told the union dudes, "hey guys, we're on to you. Either you start giving us really fine collective agreements with your union so we can make lots more money too, or we turn you in."

So the union dudes start doing real cheap deals with the employers in the know.....

Naw, that wouldn't even happen on the Sopranos--would it?

  • posted by siggy
  • Sat, Jul 20, 2002 9:09pm

Richard your evil thought fascinates me. See if I got it clear.

If you spend millions on an investment property, run it into the ground, sell it to a friendly dude, at a huge loss to the original investors under the guise of cutting your losses.

Then the friendly dude, who now owns a valuable property he picked up really cheap, sells it for what its worth and pockets the difference? Am I close? Geez that is evil.

  • posted by weiser
  • Sat, Jul 20, 2002 9:17pm

Gee! Now CCWIPP is in the business of lending money to lawyers.

Remember the WebGalaxy guys? And remeber the Union Labor OnLine guys, and remember the guys and remember the Asia Web Holdings guys? Well, CCWIPP is still hangin with them but now the company is called Case Financial Inc.

They should write a book about it as "The Little Investment that Could." Just when you think it's down for the count, it pops back up again with CCWIPP as a prominent shareholder.

How nice, a company that lends money so you can sue people.

  • posted by Richard
  • Sat, Jul 20, 2002 9:26pm


posted by siggy:
Richard your evil thought fascinates me. See if I got it clear.

If you spend millions on an investment property, run it into the ground, sell it to a friendly dude, at a huge loss to the original investors under the guise of cutting your losses.

Then the friendly dude, who now owns a valuable property he picked up really cheap, sells it for what its worth and pockets the difference? Am I close? Geez that is evil.

Siggy, that's the twisted thought I was having. The only thing that might need clarification would be that the "friendly dued(s) might not get to pocket the whole wad. They might have to share with the guys who provided the opportunity.

Do you think I'm twisted enough to write for the Sopranos?

  • posted by siggy
  • Sat, Jul 20, 2002 9:38pm


What if some big employers hung out on the pension board and knew what was going on. And what if they told the union dudes, "hey guys, we're on to you. Either you start giving us really fine collective agreements with your union so we can make lots more money too, or we turn you in."

So the union dudes start doing real cheap deals with the employers in the know

Let me try to understand the rest of the plot.

Now your saying that the company dudes who are also responsible for the pension monies know what's going on and instead of fixing it, they prefer to use the information to manipulate the other half of the board for their own business interest.

You are really twisted Richard. NBC will be calling you.

  • posted by Fisher
  • Sun, Jul 21, 2002 5:03am

Lets talk CCWIPP. I am a member of the unit that Downeaster refers to and before you render judgement there is more information you need. In 1995 our skilled negotiating team was able to negotiate that the company pay 58 cents per regular hour worked into CCWIPP. The amount was suggested by the CCWIPP administrators as their target sealing, this sealing was not reached causing the company to place 3 cents above the maximum amount the plan was designed to absorb. There were two other units within the UFCW in the same boat. At or about the spring of 1998 the Alberta Pension Commission determined that the plan was under funded. This determination was based on the restrictive government policy of not recognizing multi employer pension plans and requiring that every plan have adequate funding to cover all current and future expenses should the employer go under. The CCWIPP plan has in excess of four hundred employers and members in excess of one hundred thousand participants. Should all the employers represented go under the entire Canadian economy would collapse. So negotiations began between the CCWIPP plan and the Alberta Pension Commission. Now there are only two ways for a pension plan to raise funding short of increasing membership and they are reduce benefits and/or increase the cost of those benefits. The administrators brokered a deal that would give it time to address this issue without infringing on it's members accumulated pension credits, the age group exempt from the age 60 reductions attests to this. The plan has now moved to Ontario and the work on rebuilding the benefits back to previous levels is underway as the Ontario government recognises to a greater extent multi employer pension plans. Now lets talk turkey, governments have traditionally placed roadblocks in front of labour when it tries to benefit it's members. The unrealistic requirement of the Alberta Pension Commission would never be placed on management when trying to fund an enterprise but when the working man wants to take advantage of this style of funding so as to increase the return to the maximum advantage of the workers they raise red flags. Is this the fault of the UFCW or the CCWIPP administrators I say no it is simply an example of the double edged sword that labour has fought against for generations. An even playing field is still just a dream in Canada. Here is a question that I have asked but no-one has been able to answer, is there any pension plan out there open to us that pays more than CCWIPP? The workers at Garden Province Meats have only been in CCWIPP for a short time, about fifteen years. Prior to this we were in the Canada 100 Canada Packers Pension Plan ( as I understand) which was controlled by management and the union has been forced into the courts to get the employer constitutions back for it's members. Union controlled or management controlled, I choose union controlled.

In Solidarity Fisher

  • posted by HJFinnamore
  • Sun, Jul 21, 2002 7:31am

Fisher, you're spouting the Party line. You seem to be one of those who believe because you want to believe.

Like it or not, CCWIPP had solvency problems under the Alberta pension rules. That should never in a thousand years have happened. CCWIPP's problem should be what to do with the "breakage," not how to fund up to become solvent under pension rules. They should be overfunded, not underfunded.

Breakage is a term used for monies paid into a pension plan on behalf of members who permently leave the plan before becomming "vested," or eligible for retirement benefits. CCWIPP has truckloads of money pumped in for the tens of thousands of part timers who will quit before vesting.

Fisher, look at the I.F. Propcos and the way they have been used to fund RHK Capital, RHK Hotels, Chimo Hotels, Kelloryn Hotels, AFM Hospitality, the British Colonial Development Company, etc., etc.,

Hey, Fisher, how much do you know about CCWIPP buying bum hotel and signing substandard collective agreements for those hotels. How do you feel about CCWIPP as an employer?


11. A great deal of evidence was heard which detailed the interrelationship between the various actors in the workplace. The evidence establishes that Kelloryn is a single?purpose corporation, incorporated to purchase the assets of the hotel, The company was initially incorporated on August 17, 1992, with Ronald Kelly as its sole director. On that same date Ronald Kelly was appointed president, chief executive officer, secretary and, treasurer of the company. Kelloryn has issued one hundred thousand common shares, thirty thousand of which are held by Ronald Kelly, either directly or through a holding company. The remaining seventy thousand common shares are held equally by two companies I.F. Propco Holdings (Ontario) 14 Ltd. and I.F. Propco Holdings (Ontario) 16 Ltd. ("hereinafter referred to as "Propco 14" and "Propco 16", respectively).

12. By way of a loan agreement dated October 7, 1992, Propco 14 advanced to the company a loan in the amount of seven million dollars. A shareholders agreement of same date was entered into between Ronald Kelly, Propco 14 and Kelloryn the terms of which were not placed before me, on May 12, 1993, Propco 16 advanced to the company a loan in the amount?of eight million dollars. A shareholder's agreement of same date, which by its terms supersedes the previous shareholder's agreement of October 7, 1292, was at that time entered into between Ronald Kelly, Kelloryn, Propco 14 and Propco 16. The loan was advanced pursuant to a loan agreemmt between the company and Propco 16 also dated May 12, 1993.

13. According to documentation provided by counsel for the responding party, consisting of a Form 1 "Notice of Change" filed by the company with the Ministry of Consumer and Commercial Relations on September 1, 1993, in October and November, 1992, the officers and directors of Kelloryn were altered significantly. On October 16, 1992, Alexander Ahee was appointed Assistant Treasurer of the company. Mr. Ahee is a Prominent counsel in the labour relations community acting for trade unions. On November 24, 1992, Mr. Ahee was also elected as a director of the company, along with five others – Edward McConnell, Clifford Evans, Howard Preston, Ronald Kelly and Hubert Kelly. Mr. Thomas Kukovica, currently the Canadian Director of the United Food & Commercial Workers International union ("the international"), testified under Subpoena that Mr. Ahee is legal counsel for the Canadian Commercial Workers industry Pension Plan ("CCWIPP"), though not for the International. He also advised that Mr. McConnell is an investment manager who works with an investment firm used by CCWIPP. Mr. Ronald Kelly testified that Mr. McConnell was a former business partner of his, that Mr. Preston and Mr. Evans (the latter having been the previous Canadian Director of the International) were appointed to the Board of Directors by Propco's 14 and 16, and that Mr. Hubert Kelly was his brother and partner....

27. Counsel for Local 75 asserted that the link between the "UFCW' and Kelloryn is highlighted by the fact that Kelloryn voluntarily signed a collective agreement with Local 206 on November 20, 1992 prior to the commencement of operations Of the hotel in December, 1992, and prior to the hiring of any employees. This suggests that, notwithstanding the control by Accomodex over labour relations disclosed by the Operating Agreement, Kelloryn still has control over selecting a bargaining agent. He noted that the evidence was clear that, when employees were hired by Accomodex on behalf of Kelloryn in November and December, 1992, the employees were all asked to sign Local 206 membership cards.

Fisher, for your information, Accomodex and AFM Hospitality are the same company.

You have a long way to go in order to understand pension plans. If you gobble up everything that's put on your plate without knowing what you're eating, you could get really sick. Do some research before you swallow anything your so-called friends feed you.

Read everything in this thread and others on this site. Read the Haunted Houses of Labour article. You may learn a lot about pension plans.

  • posted by Downeaster
  • Sun, Jul 21, 2002 7:36am

We at Canada Packers and later Garden Province Meats were in the Canada Packers (100) pension plan ,when Canada Packers Left We the members got only the money that we put into the plan and we never got the companys part ,we later found out there was something like 30 million in surplus in the pension plan which we should have gotten a part of when our plant closed down.UFCW went to the courts and the courts decission was a55 .45 split for the company and active members in the plan. We than went into the garden province Meats pension Plan and then into CCWIPP. We are constantly being asked to put more of our money into the plan to keep what we already have. The Pension Leglislations in each province are there to protect the pension members. PEI does not have pension leglislation at all ,so if the solvency leglislation gets to tought in Ontario than CCWIPP could transfer to PEI where there is no leglislation.

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