We participated in the OSC’s September 2017 roundtable discussion on alternatives to eliminating embedded commissions. Much of the industry participation that day was seemingly aimed at protecting themselves with little regard for clients. This must change. In particular, we urged the broader industry – particularly dealers, dealing representatives, and mutual fund manufacturers – to focus on how each of them would want to be treated as clients of the industry; and focus efforts on creating feasible ways of delivering what clients need and deserve.
We also support the OSC in pushing back against the Ontario Minister of Finance. The Minister’s statement opposing these proposals appear to be motivated by politics; not by investor protection objectives.
People investing in investment funds of all kinds should be receiving total cost transparency. While CRM2 was a good first step; meaningful investor-friendly total cost disclosure is long overdue. Since the broader industry has failed to create this transparency, it is up to regulators to legislate it. This transparency should be required regardless of the product being used. The remainder of this submission directly addresses the MFDA’s consultation questions.
The investment fund sponsors and dealers have done too little for too long to figure out a meaningful, common sense way to be transparent with their clients. As a result, we’re generally in favour of a ban on embedded commissions on financial products. Moreover, clients deserve to not only see total costs after-the-fact (through regular reporting) but to receive this transparency before taking the plunge to engage an advisory firm. Our submission on Canadian Securities Administrators’ consultation paper on eliminating embedded commissions (81-408) expands on these ideas and details our feedback on regulators’ many specific questions.
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.
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.
True and full cost disclosure is at the heart of putting clients’ interests first; and key to a transparent reporting regime.
After many incomplete efforts at regulation financial planning activities and/or titles, this submission fully supports this long overdue initiative
This submission provides a detailed analysis of regulators’ proposed risk measure and illustration along with more practical solutions to improve upon the status quo
While being supportive of the idea of putting clients’ interests above all, imposing this duty is unlikely to achieve regulators’ end goal
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.