The Consultation Summary Report (Report) summarizes the comments received from the second public consultation on the proposed Financial Planner/Financial Advisor (FP/FA) title protection framework and FSRA’s responses to those comments.

FSRA would like to thank all of the stakeholders who invested the time and effort to engage with FSRA during the consultation process.


FSRA re-posted the revised Financial Professionals Title Protection Rule (FPTP Rule) and proposed Guidance – Financial Professionals Title Protection – Administration of Applications (Application Guidance) for a 40-day public consultation from May 11 to June 21, 2021. FSRA also posted new proposed Guidance – Financial Professionals Title Protection – Supervisory Framework (Supervision Guidance) for consultation.

The proposed FPTP Rule and guidance outline the parameters for the implementation of the FP/FA title protection framework. These documents set out:

  • the requirements and standards that entities would be required to meet in order to obtain FSRA approval as a credentialing body (CB), and to obtain FSRA approval of a Financial Planner (FP) or Financial Advisor (FA) credential;
  • FSRA’s proposed approach to the administration of applications for CBs and FP/FA credentials under the Financial Professionals Title Protection Act, 2019 (FPTPA); and
  • FSRA’s proposed approach to supervision under the FPTPA and the FPTP Rule.

Stakeholder Feedback

FSRA received 27 written submissions and 1 question during the second consultation.

In their responses, stakeholders expressed continued overall support for the implementation of a title protection framework for FP and FA title users in Ontario.

This Report focuses on new comments and questions raised during the second consultation, as well as FSRA’s responses. The Report does not include questions and comments received from stakeholders as part of the second consultation that were already included in the consultation summary report produced following the first public consultation. A summary of the comments received during the first public consultation is outlined in the Consultation Summary Report.

A full list of respondents to the second public consultation is provided in Appendix A of this document.

Following the conclusion of the second public consultation, FSRA has made several updates to the proposed Application and Supervision Guidance. The revised documents have been posted for an additional 28-day public consultation.

Appendix A – List of Commenters

Outlined below is a list of stakeholders that provided written comments for the second consultation on the proposed FPTP Rule and related Guidance that ran from May 11 to June 21, 2021.

Consumer/Investor Advocates

Fair Canada
FSRA Consumer Advisory Panel
Kenmar Associates
OSC Investor Advisory Panel

Industry/Trade Associations

Canadian Bankers Association
Canadian Credit Union Association
Canadian Life and Health Insurance Association
Financial Planning Association of Canada
Independent Financial Brokers of Canada
Investment Industry Association of Canada
The Benefits Alliance Group

Professional/Designation Bodies and Education Providers

Canadian Institute of Financial Planning
Canadian Securities Institute
CFA Institute / CFA Societies Canada
CPA Ontario
FP Canada
Institute of Advanced Financial Planners
Knowledge Bureau
Portfolio Management Association of Canada


Primerica Financial Services Limited

Self-Regulatory Organizations

Investment Industry Regulatory Organization of Canada
Mutual Fund Dealers Association of Canada

Other Submissions

Andrew Teasdale
Ontario Pension Board
Royal Bank of Canada