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Advocis-CALU joint response to B.C.’s consultation on insurance rebating (September 16, 2019)

The B.C. Ministry of Finance is reviewing the Financial Institutions Act and Credit Union Incorporation Act. As part of its review, B.C. is proposing modifications to the way that insurance rebates are calculated. In a joint submission from Advocis and CALU, we argue that the practice of insurance rebating for life and health products should be outright prohibited, as rebating creates a series of consumer protection concerns that cannot be justified by an underlying policy rationale.

The Saskatchewan Financial and Consumer Affairs Authority’s review of the regulation of the “Financial Advisor” and “Financial Planner” titles (September 9, 2019)

The Financial and Consumer Affairs Authority of Saskatchewan asked stakeholders to provide their thoughts on the regulation of the titles of “financial advisor” and “financial planner”, and particularly as to whether the province should mirror the approach taken by Ontario in its 2019 Budget. In Advocis’ response, we say that both titles must be protected as they represent two related but separate qualifications, and that mirroring Ontario’s approach would promote harmonization, which is key for consumer protection.

MFDA Proposed Amendments to Discretionary Trading (August 2, 2019)

Advocis commends the MFDA for listening to industry feedback and acting to reduce regulatory burden through the proposed amendments, which would allow Members to engage in very limited discretionary trading in respect of dealer-administered mutual fund model portfolios. In our view, the proposed amendments are an appropriate method to reduce unnecessary costs and administrative burden for Members, with the added benefit of reducing consumer confusion and enhancing investor protection.

OSC Statement of Priorities for 2019-2020 (May 27, 2019)

Advocis comments on the Ontario Securities Commission’s draft Statement of Priorities for 2019-2020. We discuss: the need to identify, measure and address regulatory burden, pointing to cost-benefit analyses, outside business activities, the client-focused reforms and the role of regtech; how to improve retail investors’ experience; our support for the Capital Markets Regulatory Authority; and the role of innovation and fintech.

2019 Ontario Budget Consultations (February 8, 2019)

Advocis commends the Government of Ontario’s commitment to reviewing the regulatory oversight of financial advisors and planners in the province. We discuss how the Government’s vision aligns with Advocis’ 2018-2022 strategic plan and commitment to advance the value and professionalism of advisors, in the best interest of consumers.

CSA Proposed Amendments to NI 81-105 (December 13, 2018)

Advocis understands that certain mutual fund sales practices can be misapplied by unprofessional advisors and this problem needs to be addressed. But the outright elimination of the DSC option would be the incorrect policy response. DSC is a tool; it is not inherently problematic and should be preserved as an option. Instead, there are better ways to strengthen consumer protection.

CSA Proposed Amendments to NI 31-103 (October 19, 2018)

The CSA’s client-focused reforms are promising, but they would be layered upon a product-based framework that does not reflect modern advice-giving. The reforms are also too narrowly focused on costs, and not value. The handling of conflicts of interest and disclosure require greater clarity. And the CSA’s approach to referral arrangements needs a complete re-think.

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