ID
2023-005

Type
Rules
Sector
Cross Sector
Status
Public comment closed
Date
Comment Due Date

Thank you for providing your feedback on FSRA’s proposed 2022 Fee Rule.

We appreciate the comments and questions received to date. Your feedback will help to inform our final 2023-26 Annual Business Plan.

The request for submissions is now closed.

FSRA is proposing an amendment to the Fee Rule that, if approved, would reduce New SRO’s fees, recognizing that the Ontario Securities Commission (OSC) already provides oversight of its activities. 

FSRA, the OSC, and New SRO are working together to ensure that New SRO’s participation as a credentialing body under the title protection framework would not result in regulatory duplication.

Consultation on the proposed amendment is now open and will close on June 2, 2023. A final proposed Fee Rule will be submitted to the Minister of Finance for approval following the review of the consultation feedback. 

During the first consultation, FSRA received over 20 stakeholder submissions and comments. Overall, Stakeholder feedback strongly supports the implementation of an updated fee structure, and therefore, there are no other substantial changes to the Fee Rule.

Full details of the proposed change and a summary of stakeholder feedback are now available:

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Before we begin, please make sure you do not include any personal or private financial information. If your inquiry does require this information be shared with us, please call us at 1-800-668-0128 or email us at [email protected] for instructions.

By submitting your content, you agree to have your materials posted on our engagement portal, used in reports and other materials prepared by Financial Services Regulatory Authority of Ontario (FSRA) that may be shared with the public. Content is moderated so that all posts are respectful and professional. The Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c.F.31, applies to all online content.

Sector Comment Date posted
Financial Planners and Advisors
[2023-005] The Financial Planning Association of Canada

[2023-005] Ken Kivenko - Kenmar Associates
[2023-005] Andrew Teasdale

Financial Planners and Advisors
[2023-005] Bruce McPherson - FAIR Canada
Financial Planners and Advisors
[2023-005] Vaughn Hoskins - Hoskins Wealth
This response is regarding the fees applicable to members under the Financial Advisor/Financial Planner Title Protection framework.

This year I have paid an FSRA regulatory fee for both my CLU and my CFP renewal.

My initial view on the FSRA regulatory fees was that I should not have to pay a separate fee for each qualifying designation. Now that I’ve taken time to reflect on it, I question whether I should be paying any FSRA regulatory fee period let alone paying an FSRA regulatory fee for each separate designation. The financial advisory industry is riddled with individuals lacking the proper degree of expertise – shouldn’t regulatory efforts including fees be focused there?

When I reflect on the title protection framework I find myself dissatisfied. Now that a myriad of designations have been accepted (when this was the one time we could have gotten somewhat close to a harmonized standard) my opinion is that the general public will view designations such as the QAFP as being equivalent to the CFP simply because the title protection framework allows use of the same title under either. Simply put, people are not going to do the research in most areas in Canada to be able to distinguish. How I am supposed to convince someone that the CFP is a higher standard than another qualifying designation when the framework says either permits someone to hold the Financial Planner title.

When I wrote the CFP in June 2019 there were 717 writers. The last writing had only 259 writers. I can’t help but feel there is a correlation with the recent decrease in writers and the new framework (even factoring in the surge that took place prior to requiring a university degree).

In closing, although this submission is supposed to be solely about regulatory fees, my view on the title protection framework influences my opinion on paying FSRA fees. The regulatory charges and effort (in my opinion) should be put into monitoring those that do not spend the time on knowledge advancement and professional credentials/development. At present, I do not believe that the title protection framework benefits me whatsoever.

[2023-005] IIAC Public Affairs - Investment Industry Association of Canada

Financial Planners and Advisors
[2023-005] Keith Costello - Canadian Institute of Financial Planning (CIFP)
Re: FSRA's Proposed Fee Rule -- 2nd Consultation

Thank you for your request for comment letters regarding this important consumer protection initiative regarding the use of the titles ‘Financial Planner’ and ‘Financial Advisor’ in Ontario and specifically, on the proposed amendment to the Assessments and Fee Rule (FSRA Fee Rule).
The Canadian Institute of Financial Planning (CIFP) is pleased to represent the views of its more than 7,000 students. Further, our submission also incorporates the comments of our affiliate member organization, The Canadian Institute of Financial Planners (CIFPs), which represents over 10,000 members.

Thank you for taking our comments into consideration.
Financial Planners and Advisors
[2023-005] Devin Mataseje - FP Canada
Financial Planners and Advisors
[2023-005] Paniz Ghazanfari - Advocis, the Financial Advisors Association of Canada
To Whom It May Concern:

Please find enclosed the Advocis response to the proposed amendments to FSRA's Fee Rule.

Thank you for your consideration.

Best Regards,
Paniz Ghazanfari
Associate Director, Legal and Regulatory
Advocis
Financial Planners and Advisors
[2023-005] Jason Watt - Business Career College
Please find our comment attached. Thank you for the opportunity.
[2023-005] Consumer Advisory Panel to The Financial Services Regulatory Authority 0f Ontario (FSRA)
The Consumer Advisory Panel had the opportunity to participate in this consultation. The Panels official submission provided in the attached document.
Pensions
[2023-005] Brian Jenkins - ActuBen Consulting
No questions have been asked about this consultation yet.