Summary of the Meeting November 28, 2022

1. Opening Remarks

FSRA executives thanked members of the Stakeholder Advisory Committee (SAC) for attending and emphasized the importance of having a diverse group of industry stakeholders providing FSRA with their feedback on the Financial Professionals Title Protection Framework (FPTPF).

FSRA executives briefly remarked on the objective of the Financial Professionals Title Protection Act, 2019 (FPTPA) and how the FPTPF establishes parameters to ensure continued consumer protection in Ontario.

2. Approved Credentialing Bodies and Credentials

FSRA management informed the SAC of the four (4) credentialing bodies (CBs) and nine (9) credentials that have been approved by FSRA under the framework as of November 28, 2022.

3. FSRA’s Supervision Approach

FSRA management provided an overview of FSRA’s supervision plan, which is intended to:

  • ensure continued compliance
  • assess CBs’ readiness for potential future enhancements to the framework;
  • identify any inconsistencies between CBs’ existing practices and standards; and
  • promote enhancement and standardization of minimum standards based on best practices.

FSRA management noted the four (4) areas of supervision for 2023/24 will focus on:

  1. The “putting the client’s interest first” principle;
  2. Resource stress testing;
  3. Complaint handling process; and
  4. Disciplinary process

SAC members suggested that FSRA should publish the results of its supervision findings to promote transparency. FSRA noted it intends to publish the aggregate results, consistent with FSRA’s other regulated sectors.

“Putting the client’s interest first” principle

FSRA and SAC members discussed the principle of “putting the client’s interest first”, how it can be consistently implemented across all CBs, and the need to ensure that CBs are held accountable for non-compliance.

Continuing education exemptions for retired / non-practicing credential holders

A SAC member raised concerns that continuing education (CE) requirements under the FPTPF pose challenges for retired / non-practicing credential holders and suggested FSRA should consider an exemption for individuals who fall under this category. FSRA staff noted this is something that they will consider further.

Publishing the terms and conditions of CB approval

SAC members provided a number of ideas as to what should be published and how it should be published based on the guidance. FRSA noted these ideas and will consider as part of the implementation.

Information Sharing

SAC members discussed the benefits of information sharing between approved CBs, but also suggested that FSRA should be involved in operationalizing and facilitating the development of the information-sharing processes between FSRA-approved CBs and the self-regulatory organizations (SROs) / new SRO.

4. FP/FA Education Campaign

FSRA management provided an overview of the first FP/FA consumer education campaign, which was launched to raise awareness amongst consumers/investors on the FPTPF and encourage them to ask key questions when dealing with an individual that is holding out as an FP or FA.

SAC members and FSRA discussed the importance of ensuring consumers are informed on the difference between an FP and FA and the value of working with individuals who hold out as an FP or FA.

A SAC member noted the importance of providing industry participants with information on how the FPTPF may potentially affect them and the various ways individual advisors/planners can meet the minimum standards to use the FP/FA titles.

SAC members and FSRA discussed plans to measure the efficacy of the consumer education campaign and confirmed FSRA would report back to the SAC on the findings.

5. FP/FA: Outstanding Policy Items

FP/FA Public Registry

FSRA management provided an overview of the proposed public registry for individuals with an approved FP/FA credential from a FSRA-approved CB. FSRA noted it aims to launch the registry in 2023/24 to provide consumers with a one-stop tool to validate if an individual holds an approved credential to use the FP/FA titles.

SAC members and FSRA discussed what information should be included in the public registry such as, but not limited to, a credential holder’s disciplinary history, status (“in good standing” or “not in good standing”), business address, organization / company name, and scope of services offered.

SAC members noted the information on the public registry should be reasonably up-to-date to ensure consumers are accessing accurate information. SAC members also suggested FSRA should monitor activity on its website, to measure the effectiveness of the public registry.

Title Use Following Revocation of a CB’s Approval

FSRA management provided an overview of FSRA’s proposed approach with respect to how credential holders can continue to use the FP/FA title in the event a CB’s approval is revoked, or the CB ceases to operate. FSRA management noted this work is being conducted with the Ministry of Finance (MOF) as the existing provision under the FPTPA is Lieutenant Governor in Council (LGIC) Regulation-making authority.

SAC members are supportive of the proposed approach and noted there could be additional ideas that FSRA should consider, such as facilitating the transition of impacted credential holders to other CBs.

Additional Questions

SAC members and FSRA discussed FSRA’s process for reviewing the curriculum of credentials being submitted for approval. FSRA confirmed credentials are being reviewed based on FSRA’s minimum standards for FP/FA title use, which were determined based on an extensive review of several existing designations / licences in the financial services marketplace.

6. Closing Remarks

FSRA management thanked the SAC members for their time and discussion.

Appendix: Attendance Record

Invited/Attended Company Name Attendance Status (A)ttended; (R)egrets; (S)ubstitute
Anthony Williams Canadian Institute of A
Tashia Batstone FP Canada A
Marshall Beyer Canadian Securities Institute (CSI) A
Harvey Naglie Consumer / Investor advocate and member of FSRA’s Consumer Advisory Panel (CAP) A
Michael Thom CFA Societies Canada A
Moira Klein-Swormink Edward Jones A
Sheldon Stier Independent Financial Brokers of Canada (IFB) A
Jason Watt Business Career College A
Jennifer McQueen Mainstreet Credit Union A
Hartland Elcock Canadian Bankers Association (CBA) A
David Terry TD Wealth Financial Planning A
Mark White FSRA A
Huston Loke FSRA A
Glen Padassery FSRA A
Judy Pfeifer FSRA A
Hussein Lalani FSRA A
Wendy Horrobin FSRA A
Joel Gorlick FSRA A
Dan Miles FSRA A
Roy Dias FSRA A
Andrea Foy FSRA A
Dan Miles FSRA A
Mary Chan FSRA A
Kirubel Abebe FSRA A
David Ha FSRA A
Nathalia Morato FSRA A