Legal and Regulatory Affairs Submissions

2019 Submissions

2018 Submissions

Submissions Archive

2015

Advocis responds to the Cooperative Capital Markets Regulatory System regarding revised consultation draft of provincial/territorial Capital Markets Act
December 23, 2015

Advocis responds to the Preliminary Position Paper of the Expert Committee Reviewing the Mandates of the FSCO, FST and DICO
December 14, 2015

Advocis responds to the MFDA regarding standards for use of the title "Financial Planner"
December 4, 2015

Advocis responds to Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives Consultation.
September 21, 2015

Advocis responds to MFDA Request for Comments on the Development of Continuing Education.
September 21, 2015

Advocis responds to Alberta 2015 Pre-Budget consultations.
September 16, 2015

Advocis responds to the CSA regarding its proposed ETF Facts disclosure document.
September 16, 2015

Advocis responds to the BC Ministry of Finance's review of the Financial Institutions Act and Credit Union Incorporation Act.
September 15, 2015

Advocis responds to the Ontario Ministry of Finance on the Review of the Mandates of the FSCO, FST and DICO.
June 5, 2015

Advocis comments on Saskatchewan’s Bill 177, An Act respecting Insurance and Insurers and making consequential amendments to other Acts and regulations.
February 17, 2015

Advocis comments on Proposed Legislation for an Ontario Registered Pension Plan (ORPP) and an Ontario Pooled Registered Pension Plan (PRPP).
February 13, 2015

Advocis comments on the 2015 Pre-Budget Consultations.
February 3, 2015

Advocis comments on Nova Scotia's review of the Credit Union Act.
January 27, 2015

Advocis comments on Ontario's five-year review of the Credit Unions and Caisses Populaires Act, 1994.
January 15, 2015

2014

Advocis comments regarding the draft legislation for the cooperative capital markets regulatory system.
December 8, 2014

Advocis responds to IIROC Administrative Notice 14-0181 in regards to its proficiency assurance model.
November 17, 2014

Advocis responds to the Canadian Securities Administrator (CSA's) Notice and Request for Comment on Multilateral CSA Notice of Publication and Request for Comment Proposed Amendments to National Instrument 45-106 Prospectus and Registration Exemptions Relating to the Offering Memorandum Exemption and in Alberta, New Brunswick and Saskatchewan, Reports of Exempt Distribution.
June 18, 2014

Advocis responds to the Canadian Securities Administrator (CSA's) Notice and Request for Comment on Proposed Amendments to National Instrument 45-106 Prospectus and Registration Exemptions and Companion Policy 45-106CP Prospectus and Registration Exemptions; and Proposed Amendments to OSC Rule 45-501 Ontario Prospectus and Registration Exemptions; and Proposed Multilateral Instrument 45-108 Crowdfunding and Companion Policy 45-108CP Crowdfunding.
June 18, 2014

Advocis responds to the Canadian Securities Administrator (CSA's) Notice and Request for Comment on Proposed Amendments to National Instrument 45-106 Prospectus and Registration Exemptions Relating to the Accredited Investor and Minimum Amount Investment Prospectus Exemptions.
June 8, 2014

Advocis responds to the Ontario Securities Commission (OSC) draft Statement of Priorities for 2014 - 2015.
May 30, 2014

Advocis responds to the Financial Services Commission of Ontario (FSCO) draft Statement of Priorities for 2014.
May 30, 2014

Advocis responds to the CSA's Request for Comment on Proposed Amendments to National Instrument 81-101 Mutual Fund Prospectus Disclosure (Pre-Sale Delivery of Fund Facts).
May 26, 2014

Advocis responds to the Canadian Securities Administrators' Request for Comments regarding Notice 81-324, Proposed CSA Mutual Fund Risk Classification Methodology for Use in Fund Facts.
March 12, 2014

Advocis responds to the Canadian Securities Administrators' Notice and Request for Comments regarding its proposed amendments to NI 31-103, NI 33-109, NI 52-107, OSC Rule 33-506 and OSC Rule 35-502.
March 5, 2014

Advocis responds to Ontario's upcoming review of the Credit Unions and Caisses Populaires Act, 1994.
February 13, 2014

Advocis responds to Ontario Ministry of Finance regarding Ontario's Financial Planning Consultation.
February 7, 2014

2013

Advocis responds to FSCO's consultation regarding the modernization of disciplinary hearings for insurance agents and adjusters.
September 30, 2013

Advocis responds to comments on the draft regulation regarding Pension Transfers under sections 80 and 81 of the Pension Benefits Act (Ontario).
September 9, 2013

Advocis responds to the CCIR's Position Paper regarding Electronic Commerce in Insurance Products.
July 26, 2013

Advocis responds to the Ontario Securities Commission (OSC) draft Statement of Priorities for 2013 - 2014.
June 3, 2013

Advocis responds to the Financial Services Commission of Ontario (FSCO) draft Statement of Priorities for 2013 - 2014.
June 2, 2013

Advocis responds to CSA Discussion Paper and Request for Comment Regarding Mutual Fund Fees.
April 12, 2013

Advocis response to the OSC's Staff Consultation Paper: 45-710 - Considerations for New Capital Raising Prospectus Exemptions.
March 8, 2013

Advocis responds to CSA Consultation Paper 33-403 discussing the implementation of a best interests duty of care on advisors.
February 20, 2013

Advocis responds to Canadian Securities Administrators' Notice and Request for Comment on Proposed Amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, to make OBSI a mandatory dispute resolution service for investor complaints against non-IIROC or non-MFDA registrants.
February 15, 2013

Advocis comments on the revised proposed Electronic Commerce Protection Regulations under Canada's Anti-SPAM Legislation.
February 6, 2013

2012

IIROC Draft Guidance regarding compensation structures for retail investment accounts
Nov. 10, 2012

CAPSA Consultation on the Draft Defined Contribution Pension Plans Guideline
Nov. 8, 2012

Unclaimed Intangible Property Program Consultation
Oct. 19, 2012

IIROC Draft Guidance regarding Borrowing for Investment Purposes Suitability and Supervision
Oct. 4, 2012

Notice And Request For Comment On Proposed Amendments To National Instrument 31-103 Registration Requirements and Exemptions And To Companion Policy 31-103CP Registration Requirements and Exemptions – Cost Disclosure And Performance Reporting
Sep. 14, 2012

Advocis comments on the Government of Canada's proposed Pooled Registered Pension Plans Regulations
Sep. 7, 2012

Advocis response to the CSA's Request for Comment on the Implementation of Stage 2 of Point of Sale Disclosure for Mutual Funds.
Sep. 6, 2012

Advocis comment letter in response to the Nova Scotia Funeral Services Consultation.
Aug. 16, 2012

Advocis response to the Life Insurance Council of Saskatchewan Request for Comment: Life Insurance Continuing Education Requirements
Aug. 1, 2012

Submission to the CCIR on Managing General Agencies (MGAs) Distribution Channel in the Life Insurance Industry
Jun. 30, 2012

Letter the Honourable Dan Struthers, Minister of Finance for Manitoba regarding Retails Sales Tax on Group Insurance
Jun. 12, 2012

Advocis response to FSCO's Draft Statement of Priorities and Strategic Directions for Fiscal 2012-2013
Jun. 6, 2012

Response to the Ontario Securities Commission Draft Statement of Priorities for Fiscal 2012/13
May 29, 2012

Letter to Manitoba Minister of Finance regarding Retail Sales Tax on Group Insurance
May 4, 2012

Submission to CCIR regarding Electronic Commerce in Insurance
Apr. 27, 2012

2012 Ontario Pre-Budget Submission to the Ontario Minister of Finance
Mar. 6, 2012

Advocis response to Consultation Paper Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime
Mar. 1, 2012

Advocis response to CSA Staff Consultation Note 45-401 Review of Minimum Amount and Accredited Investor Exemptions
Feb. 29, 2012

Response to the Insurance Council of BC's Request for Comment - Proposal for Rule Changes relating to supervision of new agents
Jan. 13, 2012

2011

Joint Advocis / CALU response to the Federal Government's consultation on Ensuring the Effectiveness of Registered Disability Savings Plans
Dec. 15, 2011

2012 Pre-Budget Submission to Alberta Minister of Finance (November 2011)
Nov. 18, 2011

Response to Implementation of Stage 2 of Point of Sale Disclosure for mutual funds
Nov. 10, 2011

Advocis response to Consultation Paper on the Use of Third Party Back-Office Service Providers
Sep. 30, 2011

Advocis response to CSA's Cost Disclosure and Performance Reporting.
Sep. 22, 2011

Advocis response to Fighting Internet and Wireless Spam Act
Sep. 7, 2011

Advocis response to Tax Rules for Pooled Registered Pension Plans (PRPPs)
Aug. 19, 2011

Advocis response to OBSI Consultation Paper on its Suitability and Assessment Process
Jul. 25, 2011

Advocis response to Financial Services Commission of Ontario Draft Statement of Priorities and Strategic Direction for Fiscal 2011-2012
Jun. 6, 2011

Advocis response to Ontario Securities Commission Draft Statement of Priorities for Fiscal 2011/12
Apr. 27, 2011

Advocis comments regarding Negative Option Billing Regulations
Apr. 12, 2011

Advocis response to Updated Draft IIROC Guidance Notice MR0281: “Guidelines for the review, supervision and retention of advertisements, sales literature and correspondence"
Apr. 8, 2011

Advocis response to CCIR Issues Paper: Managing General Agencies Life Insurance Distribution
Apr. 8, 2011

Advocis response to Framework for Pooled Registered Pension Plans
Mar. 31, 2011

Response to Consultation on Possible Options for the Incorporation of Individual Representatives of Registered Dealers and Advisers in Canada
Feb. 25, 2011

2011 Ontario Pre-Budget Submission to the Legislative Assembly of Ontario Standing Committee on Finance and Economic Affairs
Jan. 31, 2011

Advocis response to PEI Consultation on Bill 30 Pension Benefits Act
Jan. 31, 2011

Response to Insurance Council of Manitoba's Consultation on the Regulation of Incidental Selling of Insurance
Jan. 20, 2011

2010

Submission to Gerry Matier, Executive Director, Insurance Council of BC
Dec. 17, 2010

Submission to Department of Finance Canada regarding Review of Legislation Governing Federally Regulated Financial Institutions
Nov. 18, 2010

Response to the Nova Scotia Department of Finance regarding Mechanisms for Enhancing the Retirement Income System in Canada
Oct. 15, 2010

Submission to the Select Standing Committee on Finance and Government Services
Oct. 15, 2010

Letter sent to the Canadian Securities Administrators regarding CSA Notice and Request for Comments
Sep. 27, 2010

Submission to the Hon. Tony Clement, Minister of Industry
Sep. 21, 2010

  • Bill C-27, The Electronic Commerce Protection Act Submission
  • Appendix A of Advocis’s Brief on the Proposed Electronic Commerce Protection Act

  • Response to IIROC’s Proposed Rule on Personal Financial Dealings with Clients and Amendments to IIROC Dealer Member Rule 18.14
    Aug. 26, 2010

    Joint Advocis – CALU submission to the Canada Revenue Agency
    Jul. 6, 2010

    Submission to Finance Canada regarding Status of Financial Services Under the Excise Tax Act
    Jun. 28, 2010

    Letter to Saskatchewan Ministry of Finance regarding Canada’s Retirement Income System
    May 31, 2010

    Letter to BC Minister of Finance regarding Proposed Regulations pursuant to the Insurance Amendment Act, 2009
    May 31, 2010

    Submission to the Financial Services Commission of Ontario regarding FSCO Statement of Priorities
    May 18, 2010

    Submission to the Government of New Brunswick in response to their consultation on Retirement Income Adequacy
    May 14, 2010

    Submission to the Task Force on Financial Literacy in response to their consultation Leveraging Excellence
    May 4, 2010

    Submission to the Federal Government in response to the Retirement Income System Federal Consultations
    Apr. 30, 2010

    Submission to the Government of Manitoba in response to their consultation Mechanisms for Expanding Pension Coverage and Retirement Income Adequacy in Canada
    Apr. 30, 2010

    Letter regarding Representation of Advisors on the MFDA Board.
    Apr. 22, 2010

    Submission to the government of Nova Scotia in response to their Pension Consultations
    Apr. 16, 2010

    Submission to the government of British Columbia in response to their Pension Consultations
    Apr. 16, 2010

    Submission to the government of Alberta in response to their Pension Consultations.
    Apr. 16, 2010

    Response to the Consultation on Proposed Regulations pursuant to the Insurance Amendment Act, 2009
    Apr. 16, 2010

    Response to the Canadian Radio-television Telecommunications Commission regarding Telecom Notice of Consultation CRTC 2010-130.
    Apr. 6, 2010

    Letter to the Tax Policy Branch, Finance Canada regarding Status of Financial Services Under the Excise Tax Act.
    Mar. 23, 2010

    Submission to the Canadian Council of Insurance Regulators and Canadian Insurance Services Regulatory Organization
    Mar. 22, 2010

    Advocis has provided the Canadian Securities Transition Office (CSTO) with input as they proceed in drafting legislation.
    Mar. 18, 2010

    Submission to the Canadian Council of Insurance Regulators regarding its Strategic Plan 2011-2013
    Feb. 26, 2010

    Letter regarding the Ontario-Quebec Trade and Cooperation Agreement
    Feb. 22, 2010

    Submission regarding Draft Delay Acknowledgement for Life Insurance Replacement Declaration (LIRD) and Written Comparative Analysis
    Feb. 8, 2010

    Submission regarding Draft Guideline to Licensees – Sale of Segregated Funds
    Feb. 5, 2010

    2010 Pre-Budget Submission to the Legislative Assembly of Ontario Standing Committee on Finance and Economic Affairs
    Feb. 3, 2010

    Letter regarding Incorporation of Mutual Fund and Securities Advisors
    Jan. 21, 2010

    2009

    Submission regarding Incorporation of Registered Salespersons
    Dec. 17, 2009

    Letter regarding Improving Canada’s Retirement Income System
    Dec. 14, 2009

    Letter regarding Improving Canada’s Retirement Income System
    Dec. 9, 2009

    Letter regarding Improving Canada’s Retirement Income System
    Dec. 7, 2009

    Letter regarding Improving Canada’s Retirement Income System
    Dec. 7, 2009

    Letter regarding Insurance Business (Bank & Bank Holding Companies) Regulation
    Nov. 11, 2009

    Submission regarding CSA NOTICE 81-318 - Request for Comment Regarding Framework 81-406 Point of sale disclosure for mutual funds.
    Oct. 16, 2009

    Submission regarding Telecom Information Bulletin CRTC 2009-282
    Oct. 6, 2009

    Submission regarding Bill 6 Insurance Amendment Act 2009
    Oct. 2, 2009

    Submission to Alberta Finance and Enterprise regarding Consultation on Proposed Regulations for the Amended Insurance Act
    Oct. 1, 2009

    Submission regarding the Mutual Fund Dealers Association of Canada’s Proposed Amendments to MFDA Rule 2.4.1 Payment of Commissions to Unregistered Corporation
    Sep. 17, 2009

    Letter re. Alberta’s Credit Union Act & TILMA
    Sep. 9, 2009

    Submission regarding the Consultation on Unlocking Pension Funds
    Sep. 8, 2009

    Letter regarding the Regulation of the Incidental Sale of Insurance
    Aug. 28, 2009

    Submission regarding Bill C-27, The Electronic Protection Act
    Aug. 14, 2009

    Submission to Mutual Fund Dealers Association of Canada
    Jul. 23, 2009

    Submission regarding Ontario Securities Commission 2009-2010 Statement of Priorities
    Jun. 1, 2009

    Letter to regarding Reform of Pensions in Saskatchewan
    May 25, 2009

    Submission regarding FSCO Statement of Priorities
    May 21, 2009

    Submission regarding its Review of the Amendments to the Credit Union Act, 1998
    May 12, 2009

    Letter regarding Bill 20, Civil Enforcement Amendment Act, 2009
    May 7, 2009

    Letter regarding Bill 11: Act Respecting Credit Unions
    May 6, 2009

    Letter regarding the Registered Deposit Brokers Association (RDBA)
    Apr. 30, 2009

    Letter regarding Advocis Response to the OSC Statement to the Standing Committee on Government Agencies
    Apr. 24, 2009

    Letter regarding Life Insurance Replacement Disclosure Requirements
    Apr. 16, 2009

    Submission regarding Pension Reforms and the Expert Commission on Pensions Report
    Apr. 8, 2009

    Submission regarding Advisor Incorporation
    Apr. 7, 2009

    Submission regarding Regulation of Incidental Sale of Insurance
    Apr. 2, 2009

    Submission regarding Regulation of the Incidental Sale of Insurance
    Mar. 26, 2009

    Submission regarding Proposed Ontario Regulation to be made under the Credit Unions and Caisses Populaires Act, 1994
    Mar. 24, 2009

    Submission regarding Intermediary Regulation Committee Consultation Session
    Mar. 23, 2009

    Submission regarding Reform of Pension Standards Legislation in British Columbia
    Mar. 23, 2009

    Submission regarding GST – PST Harmonization
    Mar. 23, 2009

    Submission to the Standing Committee on Government Agencies of the Legislative Assembly of Ontario
    Feb. 23, 2009

    Submission to Ms. Paige Ward, Director of Policy and Regulatory Affairs regarding Principal Protected Notes.
    Feb. 20. 2009

    Submission regarding the Joint Forum Strategic Plan 2009-2012
    Jan. 19, 2009

    2009 Ontario Pre-Budget Submission to the Legislative Assembly of Ontario Standing Committee on Finance and Economic Affairs
    Jan. 16, 2009

    2008

    CSA Notice 81-318 – Request For Comment regardLetter regarding Telecom Public Notice CRTC 2008-14: Call for comments on potential modifications to some Unsolicited Telecommunications Rulesing Framework 81-406 Point of sale disclosure for mutual funds and segregated funds.
    Dec. 19, 2008

    Letter regarding Telecom Public Notice CRTC 2008-14: Call for comments on potential modifications to some Unsolicited Telecommunications Rules
    Dec. 3, 2008

    Incorporation of Licensed Salespersons
    Nov. 20, 2008

    Bill 119, Workplace Safety and Insurance Amendment Act, 2008
    Nov. 18, 2008

    Incorporation letter to Manitoba
    Nov. 17, 2008

    Letter re. Alberta’s Credit Union Act
    Nov. 12, 2008

    Letter re: Regulation of Financial Planning
    Nov. 11, 2008

    Incorporation letter to Saskatchewan
    Oct. 23, 2008

    Incorporation Letter to Nova Scotia
    Oct. 22, 2008

    Incorporation Letter to Ontario
    Oct. 21, 2008

    Incorporation Letter to BC
    Oct. 20, 2008

    Advocis' submission on Proposed Regulation of Incidental Sale of Insurance “ISI”
    Sep. 30, 2008

    Advocis' submission on Joint Notice and Request for Comment of Certain Recognizing Regulators of the Mutual Fund Dealers Association of Canada - Application to Amend Recognition Order: Suspension of MFDA Rule 2.4.1
    Sep. 29, 2008

    Submission regarding Newfoundland and Labrador’s Credit Union Act
    Sep. 26, 2008

    Proposed Regulation under the Substitute Decisions Act, 1992
    Sep. 12, 2008

    Advocis’ submission on MFDA Proposed Amendments to MFDA Rule 2.2 (Client Accounts) and MFDA Policy No. 2 Minimum Standards for Account Supervision
    Sep. 11, 2008

    Advocis' submission on MFDA Proposed Amendments to Rule 5.3 (Client Reporting) and MFDA Rule 2.8 (Client Communications)
    Sep. 11, 2008

    Advocis' submission to the Investment Industry Regulatory Organization of Canada (IIROC) regarding the Proposed Financial Planning Rule.
    Sep. 8, 2008

    Advocis' Comments to MFDA Proposed Amendments to MFDA By-Law No. 1, Sec. 25.4
    Jul. 16, 2008

    Advocis' submission regarding Creating an Advantage in Global Capital Markets
    Jul. 15, 2008

    Advocis' submission regarding Incorporation of Licensed Salespersons
    Jun. 26, 2008

    Advocis' submission regarding CSA Proposed National Instrument 31-103 Registration Requirements
    May 29, 2008

    Advocis' submission regarding Government of Ontario Draft Act Amendments Proposed National Instrument 31-103 Registration Requirements
    May 29, 2008

    Advocis's submission regarding FSCO Statement of Priorities – June 2008
    May 29, 2008

    Submission to Securities Commission regarding Ontario Securities Commission’s Draft Statement of Priorities for Fiscal 2008/09
    May 29, 2008

    Advocis’ submission to the IDA regarding Implementation of the Client Relationship Model
    May 21, 2008

    Advocis' Comments Regarding Incidental Selling of Insurance
    Apr. 28, 2008

    Advocis' Response to CCIR - An Approach to Risk-based Market Conduct Regulation
    Feb. 29, 2008

    Advocis' Submission re: Section 158 of the Securities Act of PEI - Calls to Residences
    Feb. 8, 2008

    Advocis' Submission re: Proposed Changes to Continuing Education for Life Insurance Agents
    Jan. 30, 2008

    2007

    Advocis’ Submission re: Reviewing Ontario’s Pension System
    Nov. 21, 2007

    Advocis' Submission re: Guidance Notes for the Marketing and Sale of Segregated Funds
    Nov. 2, 2007

    Advocis’ Submission on the Proposed Framework 81-406 Point of Sale Disclosure for Mutual Funds and Segregated Funds
    Oct. 15, 2007

    Advocis' Submission re: Proceeding to consider the delegation of the Commission’s investigative powers with regard to Unsolicited Telecommunications Rules complaints – Telecom Public Notice CRTC 2007-15
    Oct. 1, 2007

    Advocis' Submission re: Proposed Segregated Fund Marketing Guideline
    Aug. 3, 2007

    Advocis' Submission re: Recognition of Mutual Fund Dealers Association as a Self-Regulatory Organization in the Province of Manitoba
    Jul. 13, 2007

    Advocis' Submission to the Canadian Securities Administrators (CSA) re: The CSA's Proposed Registration Requirements, National Instrument 31-103
    Jun. 27, 2007

    Advocis' Submission to OSC re: OSC's Draft Statement of Priorities 2007/08
    Jun. 11, 2007

    Advocis' Comments on the June 2007 Financial Services Commission of Ontario Draft Statement of Priorities
    Jun. 1, 2007

    Advocis Submission to the Supreme Court of Canada, March 28, 2006
    Mar. 28, 2006

    Advocis' Submission regarding the Incorporation of Licensed Salesperson
    May 11, 2007

    Advocis' Submission regarding the Insurance Act Review Discussion Paper
    May 1, 2007

    Advocis' Submission regarding the Proposed Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
    Apr. 10, 2007

    Advocis' Submission to the Manitoba Securities Commission regarding incorporation of licenced salespersons
    Mar. 23, 2007

    Advocis' Submission to the Canadian Council of Insurance Regulators (CCIR) Working Group on Privilege regarding its Discussion Paper on Privilege and Whistle-Blower Protection and the revisions to the draft privilege model
    Mar. 9, 2007

    Advocis’ Submission to the New Brunswick Securities Commission regarding formal recognition of the Mutual Fund Dealers' Association and suspension of MFDA Rule 2.4.1 with respect to incorporated salespersons
    Jan. 12, 2007

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