Regulatory Submission Papers

Multiple Submissions to Securities Commissions | Canadian Securities Administrators Consultation Paper – 33-404

The Canadian Securities Administrators (CSA) have proposed: a) a host of rule changes; and b) that all ‘investment-licensed advisors’ should be held to an overarching Best Interest standard of care with respect to their clients.  We agree with most of the proposed rule changes.  And while we agree with applying a Best Interest standard in theory – i.e. HighView is already held to this standard – we are warning the CSA that applying this standard to the existing industry structure may not change today’s two-tiered system of investor protection in Canada.

Submission to Securities Commissions | CSA Mutual Fund Risk Classification Methodology

The CSA’s proposal for standardized risk measurement and illustration is a significant improvement over the status quo.  But we stand by our view in urging the CSA to discard opaque and academic risk measures; and embrace more intuitive risk measures that are aligned with how end investors actually view investment risk.

Submission to Mutual Fund Dealers Association of Canada | Measurement and Disclosure of Total Investor Costs

True and full cost disclosure is at the heart of putting clients’ interests first; and key to a transparent reporting regime.

Submission to Ontario’s Ministry of Finance | Consultation on the proposed regulation of Financial Planning

After many incomplete efforts at regulation financial planning activities and/or titles, this submission fully supports this long overdue initiative

Submission to the Canadian Securities Administrators (CSA) | Input on how best to measure and summarize investment fund risk

This submission provides a detailed analysis of regulators’ proposed risk measure and illustration along with more practical solutions to improve upon the status quo

Submission to the Canadian Securities Administrators (CSA) | Imposing a fiduciary duty on all financial advisors

While being supportive of the idea of putting clients’ interests above all, imposing this duty is unlikely to achieve regulators’ end goal

Submission to Morningstar Canada | New fund classification regime

At a time when Morningstar Canada proposed to create its own fund classification system – which have some regulatory impact – this submission shares thoughts to improve an already good proposal.


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