June 6, Expert Committee:
|
|
- Barry Clark
- 6 years ago
- Views:
Transcription
1 June 6, 2016 Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives c/o Frost Building North, Room th Floor, 95 Grosvenor Street Toronto, Ontario M7A 1Z1 Expert Committee: The Canadian Life and Health Insurance Association (CLHIA) is pleased to provide comments on the Expert Committee's preliminary policy recommendations as set out in Financial Advisory and Financial Planning Policy Alternatives. Established in 1894, CLHIA is a voluntary trade association that represents the collective interests of its member life and health insurers which, together, account for 99% of the life and health insurance in force in Canada. Our members contribute to the financial well-being of millions of Canadians by providing a wide range of financial security products, including almost $4.2 trillion of life insurance coverage. During 2014 in Ontario, life and health insurers made benefit payments of $40.3 billion, or roughly $775 million a week, to policyholders and beneficiaries. The industry has 67 head offices in Ontario, employs approximately 69,100 people, and invests over $265 billion in the provincial economy. In a letter dated July 27, 2015 CLHIA provided comments on the Expert Committee's initial consultation. Throughout this letter, "initial response" refers to that letter. In our initial response, we suggested that fundamental change to the existing regulatory framework for financial services is not required and that it is more appropriate to address existing gaps in a more targeted regulatory approach. We are pleased that the Expert Committee agrees with this approach and is recommending more targeted regulation to address issues it has identified. We believe the Expert Committee's specific recommendations, taken as a whole, reinforce the distinction between financial planning and financial advising that we made in our initial response. As discussed below, we believe the best way to reinforce this distinction is to focus on regulating those who hold themselves out as financial planners. Regulation of Financial Planning We agree that individuals who hold out as financial planners should be regulated. Further, we strongly recommend that holding out be the basis of regulation in this area. Canadian Life and Health Insurance Association 79 Wellington St. West, Suite 2300 P.O. Box 99, TD South Tower Toronto, Ontario M5K 1G Association canadienne des compagnies d'assurances de personnes 79, rue Wellington Ouest, bureau 2300 CP 99, TD South Tower Toronto (Ontario) M5K 1G Toronto Montréal Ottawa
2 We also strongly recommend against attempting to define financial planning and then regulating those who engage in that activity. The definition of financial planning in Appendix A of the Expert Committee's report is quite sweeping. The phrase "any review and analysis of present and future financial needs" could be interpreted, for example, as including the sort of needs analysis that licensed life agents do when making recommendations about life insurance. Such an activity based approach would inevitably lead to confusion as to the scope as to who is to be regulated and to unnecessary overlap with the needs analysis activities of life insurance representatives On this point, where we refer to the regulation of financial planning throughout this letter, we have in mind the regulation of those who hold themselves out as financial planners. With respect to the recommendation that the regulation be carried out by existing regulators, it is not clear how this will be implemented. If the role of the individual regulators is limited to recognizing a set of standards, this approach might be workable. If, however, the role of the regulators is broadened to involve development of standards and/or investigation and enforcement, it may be difficult to maintain consistency of regulation with this approach. Last year the Mutual Fund Dealers Association consulted on standards that should be required for registrants who hold out as financial planners. This may suggest the outline of an effective approach whereby existing regulators (i.e., the Financial Services Commission of Ontario or its successor, the Investment Industry Regulatory Organization of Canada and the Mutual Fund Dealers Association) require that their licensees who hold out as financial planners comply with a prescribed set of standards. Harmonization of Standards We agree that requirements for education, training, credentialing and licensing of persons who hold out as financial planners should be established in a single set of standards. The Expert Committee did not provide clear direction on what the standards should be. Well known and established standards for financial planning already exist and it would seem appropriate for the Expert Committee to recommend one of these. In our initial response, we recommended the standards that have been developed by the Financial Planning Standards Council. If the Expert Committee believes there are short-comings in these standards, the discussion could have been usefully advanced by identifying these weaknesses and proposing specific enhancements. Statutory Best Interest Duty In our initial response we described the duty of care that has been established by the Canadian Council of Insurance Regulators (CCIR) for managing conflicts of interest. For making recommendations about life insurance products, we believe effective consumer protection is provided by a duty to (1) put the client's interest ahead of those of the advisor, (2) disclose conflicts of interest and (3) recommend suitable products. This has proven to be an appropriate and effective standard for those providing advice about life and health insurance. 2
3 The Canadian Securities Administrators (CSA) is currently consulting on this matter. In its Consultation Paper Proposals to Enhance the Obligations of Advisors, Dealers, and Representatives Toward Their Clients, the CSA notes that there is no consensus among securities regulators on the value to the consumer of a statutory best interest standard. Of particular note, several regulators are of the view that specific targeted reforms also recommended by the CSA in the same consultation will be more effective in terms of providing protection to consumers. Turning back to the regulation of financial planning, we respectfully submit that specific targeted reforms, such as the other preliminary recommendations made by the Expert Committee, are the best way to effectively protect consumers. Exemptions If a standard is recommended that differs materially from the three principles described above, it would need to be reviewed to determine the need for exemptions. Referral Arrangements We have concerns about this recommendation. In its rationale, the Expert Committee states that consumers seeking financial advice or planning should be assured they are receiving these services from individuals with appropriate credentials and licensing. This seems to suggest that the Expert Committee views making a referral as giving advice. While a referral may be viewed as a recommendation, it does not seem reasonable to view it as financial advice. The Expert Committee appears to be contemplating a specific set of circumstances that is not typical of many referral fee arrangements. Two examples of common referral arrangements are a lawyer preparing a will for a young couple expecting their first child and an accountant preparing a tax return for a client interested in making charitable donations. In either of these situations, the lawyer or accountant may refer the client to a life agent and receive a fee for this referral. We are not aware of any regulations that require that both parties in a referral arrangement be licensed. Where referral arrangements are regulated, the general approach is to require that the licensed party disclose the nature of the arrangement, including associated compensation. Of note, the Mutual Fund Dealers Association Rule on Referral Arrangements explicitly acknowledges that the arrangement might be between a Member or Approved Person and another person or company. Finally, it should be noted that these requirements are generally intended to address conflicts of interest. The question of whether the person giving advice is licensed is effectively addressed by identifying licensed persons on a registry. For all these reasons, we strongly encourage the Expert Committee to carefully reconsider this recommendation. Titles and Holding Out We agree that individuals who hold themselves out as financial planners should be regulated. 3
4 We question the need to develop a list of approved titles for other licensed persons in the financial services industry. A number of stakeholders have commented on the variety of titles in use in the financial services industry and suggested this is a cause of confusion. We are not aware of any evidence that this variety is actually causing confusion. What is more, a short list of generic titles is not without its own difficulties. In practice, many advisors are dually licensed or possess multiple designations that qualify them as having expertise in specialized areas. Coming up with single titles that relate to even the most common combinations of licences and designations may be problematic and result in a list that is poorly understood by the consumer. The alternative of requiring that all the titles be listed on the business card is no less likely to be confusing once multiple titles are displayed. We think it is likely that the greatest confusion and uncertainty results from unregulated use of the title of financial planner. With respect to titles in other areas, a more effective approach might be to develop principles-based requirements that titles not be misleading. Central Registry Consumers are already able to check specific registries to see if an advisor is licensed. Information about a life insurance advisor's licence status in Ontario is available on Licensing Link and notices of disciplinary actions against an advisor are on Canadian Insurance Regulators Disciplinary Actions. Information about mutual fund advisors is on the National Registration Search. And the website of the Financial Planning Standards Councils has search features to find a Certified Financial Planner and to confirm a planner's certification status. A central registry would provide consumers with a convenient, one-stop source of information about persons licensed in financial services. However, creating and maintaining such a registry without duplicating existing services could be a significant undertaking and require substantial resources. For these reasons, the costs and benefits of such a registry would need to be carefully assessed before acting on this recommendation. Financial Literacy and Investor Education We agree that regulators, educational institutions and the industry all have a role to play in improving the awareness and understanding of Canadians in the area of financial services. Through CLHIA, the industry maintains a number of on-line brochures that provide consumers with up-to-date, plain language information about our products and services. As part of our active support of Canada's National Financial Literacy Strategy, we have a representative on the National Steering Committee on Financial Literacy and participate in Financial Literacy Month events. In addition, many insurance companies support the financial literacy with their own initiatives. Issues for Further Consideration While we agree that the issues identified by the Expert Committee merit further consideration, we have a couple of concerns. 4
5 The first concern relates to raising these issues as part of the recommendations. Many of the specific recommendations point to a need but offer little in the way of direction about potential solutions. For this reason, acting on them will involve considerable time and resources on the part of both regulators and the industry. More specifically, we agree that there is a need to regulate those who hold themselves out as financial planners and are concerned that identifying other issues may distract from this important task. The second concern relates to the suggestion that there is a need for a simplified approach to dealing with consumer complaints. The Financial Services OmbudsNetwork is intended to provide an accessible service for handing consumer complaints in the areas of life and health insurance, banking and securities, and property and casualty insurance. At least in the area of life and health insurance, we believe that the OmbudService for Life & Health Insurance (OLHI) is doing an effective job. Accordingly, we are not sure what the Expert Committee is contemplating when it talks of the need for a simplified approach. There may be some gaps in the service that OLHI is able to provide and these gaps may merit discussion but we do not believe the model needs to be fundamentally altered. General Conclusion We agree that persons who hold out as financial planners should be regulated and we are pleased that the Expert Committee both recognizes this need and recommends a targeted approach to developing the required regulation. In light of the importance of this issue and the models that exist for regulatory standards, the Expert Committee should consider providing more direction on what the standards for financial planners should be. We have suggested the outline for more substantive direction in our comments. If it would be helpful, we would be pleased to expand on these thoughts or respond to specific suggestions that the Expert Committee might be considering as it finalizes its recommendations. Sincerely, Original signed by Peter B. Goldthorpe Director, Marketplace Regulation Issues 5
Submission. on the Federal Budget. to the. House of Commons Standing Committee on Finance. by the
Submission on the 2018 Federal Budget to the House of Commons Standing Committee on Finance by the Canadian Life and Health Insurance Association Canadian Life and Health Insurance Association canadienne
More informationJune 17, Dear Sirs and Madam,
Expert Committee to Consider Financial Advisory And Financial Planning Policy Initiatives c/o Frost Building North, Room 458 4 th Floor, 95 Grosvenor Street Toronto, Ontario M7A 1Z1 Fin.Adv.Pln@ontario.ca
More informationJune 17, Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives. Via to:
June 17, 2016 Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives Via email to: Fin.Adv.Pln@ontario.ca Dear Sirs/Mesdames: Re: Response to Preliminary Policy Recommendations
More informationVIA ONLY. Dear Sirs and Mesdames:
June 17 th 2016 VIA E-MAIL ONLY Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives c/o Frost Building North, Room 458 4th Floor, 95 Grosvenor Street Toronto, On
More informationREGULATING FINANCIAL PLANNERS AND ADVISORS
REGULATING FINANCIAL PLANNERS AND ADVISORS Response to the Preliminary Policy Recommendations of the Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives June 17,
More informationThe Honourable Charles Sousa Minister of Finance 7 Queen s Park Crescent, 7 th Floor Toronto, ON M7A 1Y7. Sent via to:
The Honourable Charles Sousa Minister of Finance 7 Queen s Park Crescent, 7 th Floor Toronto, ON M7A 1Y7 Sent via email to: Fin.Planning@ontario.ca RE: Consultation Regulation of Financial Planners FAIR
More informationReference Document: THE APPROACH: SERVING THE CLIENT THROUGH NEEDS-BASED SALES PRACTICES
November, 2016 Reference Document: THE APPROACH: SERVING THE CLIENT THROUGH NEEDS-BASED SALES PRACTICES Canadian Life and Health Insurance Association Inc., 2016 Reference Document Introduction Background
More informationFinancial Services Commission of Ontario ( FSCO ) Draft Statement of Priorities & Strategic Directions dated April 2011
June 6, 2011 Mr. Philip Howell Chief Executive Officer and Superintendent, Financial Services Financial Services Commission of Ontario 5160 Yonge Street, Box 85 Toronto, Ontario M2N 6L9 Delivered via email
More informationFebruary 7, Dear Mr. Allen,
Frank Allen Assistant Deputy Minister Ministry of Finance Frost Building North, 4 th Floor 95 Grosvenor Street Toronto, Ontario M7A 1Z1 FPlanning.consultation@ontario.ca Dear Mr. Allen, The Canadian Securities
More informationRe: IAP Response to Regulation of Financial Planners Consultation Paper
April 16, 2018 By E-mail Ontario Ministry of Finance 7 Queen's Park Crescent, 7th floor Toronto, Ontario M7A 1Y7 Fin.Planning@ontario.ca Re: IAP Response to Regulation of Financial Planners Consultation
More information30 Eglinton Avenue West, Suite 306 Mississauga ON L5R 3E7 Tel: (905) Website: October 16, 2009
30 Eglinton Avenue West, Suite 306 Mississauga ON L5R 3E7 Tel: (905) 279-2727 Website: www.ifbc.ca October 16, 2009 To: British Columbia Securities Commission Alberta Securities Commission Saskatchewan
More informationI. FAIR Canada s Recommendations in Response to Questions Regarding the Mandate of FSCO
August 21, 2015 Expert Advisory Panel FSCO/FST/DICO Mandate Reviews Ministry of Finance Financial Institutions Policy Branch (FIPB) & Income Security & Pension Policy Division Frost Building North, Room
More informationOntario Securities Commission 20 Queen Street West 22nd Floor, Box 55 Toronto, Ontario M5H 3S8 Fax:
Ontario Securities Commission 20 Queen Street West 22nd Floor, Box 55 Toronto, Ontario M5H 3S8 Fax: 416-593-2318 comments@osc.gov.on.ca Me Anne-Marie Beaudoin Corporate Secretary Autorité des marchés financiers
More informationLIFE INSURANCE PRODUCT SUITABILITY REVIEW FINANCIAL SERVICES COMMISSION OF ONtARIO MARKEt REGULAtION BRANCH. SEptEMBER 2014
LIFE INSURANCE PRODUCT SUITABILITY REVIEW FINANCIAL SERVICES COMMISSION OF ONtARIO MARKEt REGULAtION BRANCH SEptEMBER 2014 Contents Executive Summary... 1 Purpose... 2 FSCO S Methodology... 3 Observations...
More information30 Eglinton Avenue West, Suite 740 Mississauga ON L5R 3E ; April 16, Ontario Ministry of Finance
30 Eglinton Avenue West, Suite 740 Mississauga ON L5R 3E7 905.279.2727; 1.888.654.3333 www.ifbc.ca April 16, 2018 To: Ontario Ministry of Finance Submitted by email: Fin.Planning@ontario.ca Subject: Consultation
More informationCanadian Life and Health Insurance Facts Edition
Canadian Life and Health Insurance Facts 2016 Edition President's Message Canadian Life and Health Insurance Facts, 2016 Edition presents authoritative, factual information about life and health insurance
More informationRe: Review of Legislation Governing Federally Regulated Financial Institutions
November 18, 2010 Advocis 390 Queens Quay West, Suite 209 Toronto, ON M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.8031 www.advocis.ca Ms. Jane Pearse Director, Financial Institutions Division Department
More informationJune 23, Delivered by Dear Ms. Hemmings: Pension Innovation for Canadians: The Target Benefit Plan
June 23, 2014 Ms. Lynn Hemmings Senior Chief, Payments Financial Sector Policy Branch Department of Finance Canada 140 O Connor Street Ottawa, Ontario K1A 0G5 Delivered by email: pensions@fin.gc.ca Dear
More informationVIA April 16, Re: Consultation - Regulation of Financial Planners (the Consultation Paper )
Michelle Alexander Vice President malexander@iiac.ca VIA EMAIL Fin.Planning@ontario.ca April 16, 2018 Re: Consultation - Regulation of Financial Planners (the Consultation Paper ) The Investment Industry
More informationSegregated Funds Working Group Position Paper
Segregated Funds Working Group Position Paper December 2017 This document reflects the work of regulators who are members of the CCIR. The views expressed should not be considered as legal opinions. This
More informationIIROC Amendments to Implement the CSA Registration Reform Project ( Proposed Amendments )
Susan Copland, B.Comm, LLB. Director Larry Boyce Vice President, Business Conduct Compliance Investment Industry Regulatory Organization of Canada Suite 1600 121 King Street West Toronto, ON M5H 3T9 Manager,
More informationSIPA SMALL INVESTOR PROTECTION ASSOCIATION
SIPA SMALL INVESTOR PROTECTION ASSOCIATION June 14, 2016 By email to: Fin.Adv.Pln@ontario.ca Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives c/o Frost Building
More informationRe: Proposed Amendments to NI and its Policy Re. Client Relationship Model Phase 2 (CRM2) Amendments
Naomi Solomon Managing Director nsolomon@iiac.ca Via Email October 5, 2016 British Columbia Securities Commission Alberta Securities Commission Financial and Consumer Affairs Authority of Saskatchewan
More informationPOSITION PAPER ELECTRONIC COMMERCE IN INSURANCE PRODUCTS
POSITION PAPER ELECTRONIC COMMERCE IN INSURANCE PRODUCTS This document reflects the work of regulators who are members of CCIR. The views expressed should not be considered as legal opinions. This document
More informationSeptember 16 th, 2015
TD Securities TD Bank Group TD Tower 66 Wellington Street West, 7th Floor Toronto, Ontario M5K 1A2 September 16 th, 2015 British Columbia Securities Commission Alberta Securities Commission Financial and
More informationJULY 15, Dear Sirs/Mesdames:
JULY 15, 2016 CCIR Secretariat 5160 Yonge Street, Box 85 17 th Floor Toronto, Ontario M2N 6L9 Re: SEGREGATED FUNDS WORKING GROUP ISSUES PAPER Dear Sirs/Mesdames: The Mutual Fund Dealers Association of
More informationComments on the Draft Framework for Reporting Performance Measures
August 22, 2018 Accounting Standards Board 277 Wellington Street West Fourth Floor Toronto, ON M5V 3H2 Canada Subject: Comments on the Draft Framework for Reporting Performance Measures The Canadian Securities
More informationRe: Electronic Commerce Protection Regulations Request for Comments in Canada Gazette, Part I, July 9, 2011
September 7, 2011 Advocis 390 Queens Quay West, Suite 209 Toronto, ON M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.8031 www.advocis.ca Bruce Wallace Director, Electronic Commerce Policy, Electronic
More informationMONITORING SUITABILITY OF AGENTS
MONITORING SUITABILITY OF AGENTS Ensuring suitability of agents is an ongoing compliance requirement for Barrington Wealth Partners Inc. Our compliance processes such as the initial verification for suitability
More informationPUBLIC POSITION. Meeting the Needs of Canada s Future Retirees A CALL TO TIMELY ACTION: NOVEMBER 10, 2015 SUMMARY OF CIA POSITION
NOVEMBER 10, 2015 SUMMARY OF CIA POSITION The Canadian retirement system has been the subject of several studies and much public discussion. It is at a crossroads due to the convergence of many forces
More informationNotice and Request for Comment Proposed National Instrument Derivatives: Business Conduct and Proposed Companion Policy CP
Osler, Hoskin & Harcourt LLP Box 50, 1 First Canadian Place Toronto, Ontario, Canada M5X 1B8 416.362.2111 MAIN 416.862.6666 FACSIMILE Toronto Montréal Calgary Ottawa New York September 1, 2017 SENT BY
More informationPOWER CORPORATION OF CANADA 751 VICTORIA SQUARE, MONTRÉAL, QUÉBEC, CANADA H2Y 2J3
POWER CORPORATION OF CANADA 751 VICTORIA SQUARE, MONTRÉAL, QUÉBEC, CANADA H2Y 2J3 EDWARD JOHNSON TELEPHONE (514) 286-7415 VICE-PRESIDENT, GENERAL COUNSEL TELECOPIER (514) 286-7490 AND SECRETARY October
More informationRe: Feedback on the Implementation of the Financial Services Regulatory Authority
October 26, 2017 The Hon. Charles Sousa Minister of Finance Ministry of Finance 7th Floor, Frost Building South 7 Queen s Park Crescent Toronto, ON M7A 1Y7 Dear Minister Sousa: Re: Feedback on the Implementation
More informationCode of Conduct and Problem Resolution Process. It s your satisfaction that matters
Code of Conduct and Problem Resolution Process It s your satisfaction that matters 03 Building Harmonious Relations with Businesses In an effort to build harmonious relations with businesses, National
More informationVIA
VIA E-MAIL: jstevenson@osc.gov.on.ca, consultation-en-cours@lautorite.qc.ca September 23, 2011 British Columbia Securities Commission Alberta Securities Commission Saskatchewan Financial Services Commission
More informationSarah Corrigal-Brown, Senior Legal Counsel, Capital Markets Regulation
June 18, 2014 VIA E-MAIL British Columbia Securities Commission P.O. Box 1042, Pacific Centre 701 West Georgia Street Vancouver, British Columbia V7Y 1L2 Attention: Leslie Rose, Senior Legal Counsel, Corporate
More informationBY
Scotia Securities Inc. 40 King Street West, 33rd Floor Toronto, Ontario Canada M5H 1H1 BY EMAIL: jstevenson@osc.gov.on.ca; consultation-en-cours@lautorite.qc.ca October 16, 2009 British Columbia Securities
More informationRe: Proposed National Instrument Commodity Pools & Companion Policy CP
August 5, 2000 British Columbia Securities Commission Alberta Securities Commission Saskatchewan Securities Commission The Manitoba Securities Commission Ontario Securities Commission Office of the Administrator,
More informationNATIONAL INSTRUMENT INVESTMENT DEALERS IIROC MEMBERS. regime will become effective on September 28, 2009 (subject to government
Keeping Reforms in Sight: Understanding the New Canadian Registration Requirements AUGUST 2009 www.blgcanada.com What s New? NATIONAL INSTRUMENT 31-103 INVESTMENT DEALERS IIROC MEMBERS The long-anticipated
More informationJanuary 14, c/o John Stevenson, Secretary Ontario Securities Commission 20 Queen Street West 19 th Floor, Box 55 Toronto, Ontario M5H 3S8.
Ian C.W Russell President & Chief Executive Officer January 14, 2011 British Columbia Securities Commission Alberta Securities Commission Saskatchewan Financial Services Commission Manitoba Securities
More informationRe: Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives
June 17, 2016 Advocis 390 Queens Quay West Suite 209 Toronto, ON M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.803 www.advocis.ca Expert Committee to Consider Financial Advisory and Financial Planning
More informationGifting. Charities. The donation credit
Gifting Why not use your hard-earned money to make a difference, by helping out the people you care for the most, or your favorite charity? Meanwhile, you benefit from the opportunity to reduce your taxes.
More informationa useful tool to assist clients in understanding the inherent conflicts of interest in this industry and the specific conflicts that arise at each fir
September 30, 2016 Alberta Securities Commission Autorité des marché financiers British Columbia Securities Commission The Manitoba Securities Commission Financial and Consumer Services Commission (New
More informationJohn Stevenson, Secretary Ontario Securities Commission 20 Queen Street West Suite 1900, Box 55 Toronto, Ontario M5H 3S8
October 17, 2009 John Stevenson, Secretary Ontario Securities Commission 20 Queen Street West Suite 1900, Box 55 Toronto, Ontario M5H 3S8 Anne-Marie Beaudoin, Secrétaire Autorité des marchés financiers
More informationAttention: The Secretary Me Anne-Marie Beaudoin
October 19, 2018 Submitted via email British Columbia Securities Commission Alberta Securities Commission Financial and Consumer Affairs Authority of Saskatchewan Manitoba Securities Commission Ontario
More informationRe: Revised Draft National Instrument "Registration Requirements" - Comments Submitted by Osler, Hoskin & Harcourt LLP
Osler, Hoskin & Harcourt LLP Box 50, 1 First Canadian Place Toronto, Ontario, Canada M5X 1B8 416.362.2111 MAIN 416.862.6666 FACSIMILE May 29, 2008 Toronto Montréal Ottawa Calgary New York British Columbia
More informationUse of Business Titles and Financial Designations. Rules Notice Request for Comments Dealer Member Rules
Rules Notice Request for Comments Dealer Member Rules Please distribute internally to: Internal Audit Legal and Compliance Operations Registration Research Retail Senior Management Training Contact: Rossana
More informationBY
BY EMAIL: jstevenson@osc.gov.on.ca; consultation-en-cours@lautorite.qc.ca British Columbia Securities Commission Alberta Securities Commission Saskatchewan Financial Services Commission Manitoba Securities
More informationNOTICE OF ADOPTION COMMISSION LOCAL RULE MB-001 MORTGAGE BROKERS LICENSING AND ONGOING OBLIGATIONS AND
NOTICE OF ADOPTION COMMISSION LOCAL RULE MB-001 MORTGAGE BROKERS LICENSING AND ONGOING OBLIGATIONS AND COMMISSION LOCAL RULE MB-002 MORTGAGE BROKERS FEES Introduction On 25 May 2015, the Financial and
More informationAmendments to Dealer Member Rules and Form 1 relating to the futures market segregation and portability customer-protection regime
Rules Notice Request for Comment Dealer Member Rules Comments Due By: August 16, 2017 Contact: Bruce Grossman Senior Information Analyst, Member Regulation Policy 416-943-5782 bgrossman@iiroc.ca Please
More informationManaged Portfolio Solutions: Finding clarity in a complex investment landscape
Managed Portfolio Solutions: Finding clarity in a complex investment landscape Most people invest to fulfill important goals such as buying a home funding a child s education, starting a business, purchasing
More informationRelationship Disclosure (RD)
BMO Wealth Management BMO Nesbitt Burns RDD-09/15-E Relationship Disclosure (RD) BMO Nesbitt Burns believes the best way to help you meet your investment goals is to work with your Investment Advisor to
More informationVIA lautorite.gc.ca. October 5, 2016
Financial IGM Financial Inc. 180 Queen Street West, 16th Floor, Toronto, Ontario M5V 3K1 Jeffrey R. Carney, CFA President and Chief Executive Officer VIA E-MAIL: comments @osc.gov.on.ca; consultation-en-cours
More informationAugust 15, Dear Ms Youck and Ms. Brosseau, RE: Proposed National Instrument Continuous Disclosure Obligations
Chartered Accountants of Canada Comptables agréés du Canada The Canadian Institute of Chartered Accountants 277 Wellington Street West Toronto, Ontario Canada M5V 3H2 Tel: (416) 977-3222 Fax: (416) 977-8585
More informationMcCarthy Tétrault. March 31, 2007 BY
Barristers & Solicitors Patent & Trade-mark Agents McCarthy Tétrault Box 48, Suite 4700 Toronto Dominion Bank Tower Toronto ON M5K 1E6 Canada Telephone: 416 362-1812 Facsimile: 416 868-0673 mccarthy.ca
More informationMay 29, Comments on Proposed National Instrument Registration Requirements. Dear Sirs / Mesdames,
British Columbia Securities Commission Alberta Securities Commission Saskatchewan Financial Services Commission Manitoba Securities Commission Ontario Securities Commission Autorité des marches financiers
More informationFINANCIAL PLANNING STANDARDS COUNCIL Response to CSA Notice and Request for Comment: Proposed Amendments to National Instrument and Companion
FINANCIAL PLANNING STANDARDS COUNCIL Response to CSA Notice and Request for Comment: Proposed Amendments to National Instrument 31-103 and Companion Policy 31-103CP (Reforms to Enhance the Client-Registrant
More informationRe: Managing General Agencies (MGAs) Distribution Channel in the Life Insurance Industry
Advocis 390 Queens Quay West, Suite 209 Toronto, ON M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.8031 www.advocis.ca June 28, 2012 CCIR Secretariat 5160 Yonge Street, Box 85 17th Floor Toronto, Ontario
More information30 Eglinton Avenue West, Suite 740 Mississauga ON L5R 3E7 Tel: (905) Website: September 30, 2016
30 Eglinton Avenue West, Suite 740 Mississauga ON L5R 3E7 Tel: (905) 279-2727 Website: www.ifbc.ca September 30, 2016 To: Alberta Securities Commission Autorité des marchés financiers British Columbia
More informationSeptember 30, Summary
National Bank of Canada Wealth Management s Position Statement on the CSA s Consultation Paper 33-404 entitled Proposals to Enhance the Obligations of Advisers, Dealers and Representatives Toward Their
More informationJune 7, The Secretary. 20 Queen Street West 19th Floor, Box 55 Toronto, Ontario M5H 3S8 Fax:
June 7, 2017 British Columbia Securities Commission Alberta Securities Commission Financial and Consumer Affairs Authority of Saskatchewan Manitoba Securities Commission Ontario Securities Commission Autorité
More informationApril 16, Pension Policy Alberta Finance and Enterprise #402, Terrace Building Street Edmonton, AB T5K 2C3. Dear Sir or Madam:
Advocis 390 Queens Quay West, Suite 209 Toronto, ON M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.8031 www.advocis.ca April 16, 2010 Pension Policy Alberta Finance and Enterprise #402, Terrace Building
More informationOntario Automobile Insurance Anti-Fraud Task Force
Ontario Automobile Insurance Anti-Fraud Task Force Preliminary Review of KPMG Forensic Report Dated June 13, 2012 24 July 2012 Author: Mr. Liam M. McFarlane Ernst & Young LLP Insurance and Actuarial Advisory
More informationProposed National Instrument Independent Review Committee ( IRC ) for Mutual Funds
April 8, 2004 Edgar Legzdins President & Chief Executive Officer Via Email Tel: (416) 867-7300 Fax: (416) 956-2363 John Stevenson, Secretary Ontario Securities Commission 20 Queen Street West 19 th Floor,
More informationRe: Re Publication of Proposed IIROC Dealer Member Plain Language Rule Book
Via Email: damin@iiroc.ca ;marketregulation@osc.gov.on.ca May 12, 2017 Darshna Amin Senior Counsel, Member Regulation Policy Investment Industry Regulatory Organization of Canada Suite 2000, 121 King Street
More informationRe: Pension Investment Association of Canada ( PIAC ) Comments on CSA Proposed National Instrument Derivatives: Business Conduct
August 29, 2017 British Columbia Securities Commission Alberta Securities Commission Financial and Consumer Affairs Authority of Saskatchewan Manitoba Securities Commission Ontario Securities Commission
More informationWhy IIROC Matters to You, the Investor
Why IIROC Matters to You, the Investor The Investment Industry Regulatory Organization of Canada (IIROC) regulates all investment dealers in Canada. We set high quality regulatory and investment industry
More informationReference Document: Serving Clients Through Needs-Based Sales Practices
June, 2017 Reference Document: Serving Clients Through Needs-Based Sales Practices Canadian Life and Health Insurance Association Inc., 2017 Reference Document: Serving Clients Through Needs-Based Sales
More informationNational Board of Directors, Advocis
Advocis 390 Queens Quay West, Suite 209 Toronto, Ontario M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.8031 www.advocis.ca British Columbia Securities Commission Alberta Securities Commission Saskatchewan
More informationTD Short Term Investment Class
TD Asset Management TD Short Term Investment Class 531696 (01/18) TD Mutual Funds Corporate Class Funds for the period ended This Interim Management Report of Fund Performance contains financial highlights,
More informationJoint Forum of Financial Market Regulators. Forum conjoint des autorités de réglementation du marché financier
Joint Forum of Financial Market Regulators Forum conjoint des autorités de réglementation du marché financier PROPOSED REGULATORY PRINCIPLES FOR CAPITAL ACCUMULATION PLANS A Report by the Joint Forum of
More informationJanuary 14, RE: Investor Advisory Panel ( IAP ) Seeks Input
January 14, 2011 Allan Krystie Senior Administrator, Investor Advisory Panel Ontario Securities Commission 20 Queen Street West Suite 1900, Box 55 Toronto, ON M5H 3S8 Sent via email to: iap@osc.gov.on.ca
More information30 Eglinton Avenue West, Suite 740 Mississauga ON L5R 3E7 Tel: (905) Website:
30 Eglinton Avenue West, Suite 740 Mississauga ON L5R 3E7 Tel: (905) 279-2727 Website: www.ifbc.ca June 5, 2015 Expert Advisory Panel FSCO/FST/DICO Mandate Reviews Ontario Ministry of Finance Financial
More informationWealthsimple Inc. 860 Richmond Street West, 3rd Floor, Toronto, Ontario, M6J 1C9
Wealthsimple Inc. 860 Richmond Street West, 3rd Floor, Toronto, Ontario, M6J 1C9 DELIVERED BY EMAIL October 19, 2018 British Columbia Securities Commission Alberta Securities Commission Ontario Securities
More informationConsultation Regulation of Financial Planners (the Consultation )
April 16, 2018 BY EMAIL Ministry of Finance Frost Building North, Room 458 4th Floor, 95 Grosvenor Street Toronto, Ontario M7A 1Z1 Email: Fin.Planning@ontario.ca Dear Sirs/Mesdames: Re: Consultation Regulation
More informationI gmfinancial. 180 Queen Street West, 16th Floor, Toronto, Ontario M5V 3K1. July 20, Delivered by
I gmfinancial 180 Queen Street West, 16th Floor, Toronto, Ontario M5V 3K1 July 20, 2018 Delivered by email: kwoodard@mfda.ca Ken Woodard Director, Membership Services & Communications Mutual Fund Dealers
More informationMaking a Complaint A Guide for Investors
Making a Complaint A Guide for Investors Investment Industry Regulatory Organization of Canada Protecting Investors and Supporting Healthy Capital Markets Across Canada The Investment Industry Regulatory
More informationPROPOSED GUIDELINES FOR CAPITAL ACCUMULATION PLANS
Forum conjoint des autorités de réglementation du marché financier PROPOSED GUIDELINES FOR CAPITAL ACCUMULATION PLANS April 2003 5160 Yonge Street, Box 85, 17 th Floor, North York ON M2N 6L9 Telephone:
More informationPension Risk Management: Administration Risks
Pension Risk Management: Administration Risks Our Pension Alert series on risk management have discussed financial risks and investment risks. In this third issue, we discuss administration risks which
More informationAssociation of Fundraising Professionals (AFP) Tax Incentives for Charitable Donations Submission
Association of Fundraising Professionals (AFP) Tax Incentives for Charitable Donations Submission To the House of Commons Standing Committee on Finance January 17, 2012 Association of Fundraising Professionals
More informationA Provincial/Territorial Memorandum of Understanding Regarding Securities Regulation
A Provincial/Territorial Memorandum of Understanding Regarding Securities Regulation BETWEEN: The Governments of the participating jurisdictions represented by their respective Ministers responsible for
More informationResponses to the specific questions outlined in the Guide for Respondents section of the Exposure Draft, are as follows:
Chartered Professional Accountants of Canada 277 Wellington Street West Toronto ON CANADA M5V 3H2 T. 416 977.3222 F. 416 977.8585 www.cpacanada.ca Comptables professionnels agréés du Canada 277, rue Wellington
More informationPRINCIPLES AND PRACTICES FOR THE SALE OF PRODUCTS AND SERVICES IN THE FINANCIAL SECTOR
Joint Forum of Financial Market Regulators Forum conjoint des autorités de réglementation du marché financier BACKGROUNDER PRINCIPLES AND PRACTICES FOR THE SALE OF PRODUCTS AND SERVICES IN THE FINANCIAL
More informationADVISOR DISCLOSURE. An Overview. February 2007
ADVISOR DISCLOSURE An Overview February 2007 TM Trademark of The Empire Life Insurance Company. Policies are issued by The Empire Life Insurance Company. A brief history Fall 2004: insurance regulators
More informationRe: Comments on Exposure Draft 40, Intangible Assets
The Canadian Institute of Chartered Accountants 277 Wellington St. West Toronto, ON M5V 3H2 L Institut Canadien des Comptables Agréés 277, rue Wellington Ouest Toronto (Ontario) M5V 3H2 Tel/Tél. : 416
More informationVia . The Secretary Ontario Securities Commission 20 Queen Street West 22 nd Floor Toronto, Ontario M5H 3S8
Date June 6, 2018 Via Email Alberta Securities Commission Autorité des marchés financiers British Columbia Securities Commission Financial and Consumer Affairs Authority of Saskatchewan Financial and Consumer
More informationA LIFE WELL PLANNED. Providing you and your family with the support, guidance and right investment advice for each stage of your life.
A LIFE WELL PLANNED. Providing you and your family with the support, guidance and right investment advice for each stage of your life. THE RIGHT ADVICE FOR EVERY STAGE OF YOUR LIFE BUILDING YOUR WEALTH
More informationRe: Proposed National Instrument and Companion Policy Registration Requirements (the Instrument )
Ian C.W. Russell FCSI President & Chief Executive Officer June 20, 2007 John Stevenson, Secretary Ontario Securities Commission 20 Queen Street West 19 th Floor, Box 55 Toronto, Ontario M5H 3S8 Anne-Marie
More informationCANADIAN SECURITIES EXCHANGE PUBLIC INTEREST RULE CORPORATE GOVERNANCE AND EMERGING MARKETS ISSUERS GUIDANCE AND REQUIREMENTS
13.2 Marketplaces 13.2.1 Canadian Securities Exchange Public Interest Rule Amendments to Policy 4 Corporate Governance and Miscellaneous Provisions Notice and Request for Comments CANADIAN SECURITIES EXCHANGE
More informationComments on the Proposed Instrument Derivatives: Business Conduct issued by the Canadian Securities Administrators
September 14, 2018 Ms. Anne-Marie Beaudoin Corporate Secretary Autorité des marchés financiers 800, rue du Square-Victoria, 22e étage C.P. 246, tour de la Bourse Montréal Québec H4Z 1G3 Ms. Grace Knakowski
More informationRe: Consultation Regulation of Financial Planners
Ontario Ministry of Finance Fin.Planning@ontario.ca. Re: Consultation Regulation of Financial Planners The Canadian Securities Institute (CSI) is pleased to submit the following remarks in response to
More informationJanuary 2, c/o Mr. John Stevenson, Secretary Ontario Securities Commission 20 Queen Street West Suite 800, Box 55 Toronto, Ontario M5H 3S8.
Kathy Byles Director, Compliance RBC Global Services Institutional & Investor Services 77 King St. W. Royal Trust Tower 12 th Floor Toronto, Ontario M5W 1P9 Tel: 416-955-2891 Fax: 416-955-2899 E-mail:
More informationConsultation Paper December 20, 2010
Consultation Paper December 20, 2010 Consultation on Possible Options for the Incorporation of Individual Representatives of Registered Dealers and Advisers in Canada PURPOSE A working group of provincial/territorial
More informationOMBUDSMAN. Office of the. Overview ANNUAL REPORT FISCAL YEAR 2007
Office of the OMBUDSMAN ANNUAL REPORT FISCAL YEAR 2007 Overview The Office of the Ombudsman is a dispute resolution resource available to all RBC clients. The Ombudsman investigates and helps resolve financial
More informationPoint of sale disclosure for mutual funds and segregated funds
5.1.4 Framework 81-406 Point of sale disclosure for mutual funds and segregated funds Joint Forum of Financial Market Regulators Forum conjoint des autorités de réglementation du marché financier Framework
More informationPoint of sale disclosure for mutual funds and segregated funds
Joint Forum of Financial Market Regulators Forum conjoint des autorités de réglementation du marché financier Framework 81-406 Point of sale disclosure for mutual funds and segregated funds Prepared by:
More informationCHAIR AND MEMBERS COMMUNITY AND PROTECTIVE SERVICES COMMITTEE PUBLIC PARTICIPATION MEETING ON SEPTEMBER 11, 2018
TO: FROM: SUBJECT: CHAIR AND MEMBERS COMMUNITY AND PROTECTIVE SERVICES COMMITTEE PUBLIC PARTICIPATION MEETING ON SEPTEMBER 11, 2018 G. KOTSIFAS, P. ENG. MANAGING DIRECTOR, DEVELOPMENT & COMPLIANCE SERVICES
More informationGUIDE TO INCORPORATION
GUIDE TO INCORPORATION Here is a simplified guide to the steps taken to incorporate a new business corporation in Ontario. For more specific information, please refer to the Disclaimer and Copyright Notice.
More informationProtection for Your Clients
Canada Deposit Insurance Corporation Protection for Your Clients CE Module OBJECTIVE Could you imagine the dismay of depositors when they learn that the financial institution they placed their money into
More informationMay 17, Dear Ms. Pezzack:
Chartered Professional Accountants of Canada 277 Wellington Street West Toronto ON CANADA M5V 3H2 T. 416 977.3222 F. 416 977.8585 www.cpacanada.ca Comptables professionnels agréés du Canada 277, rue Wellington
More information