2024-2025 Financial Planners and Financial Advisors supervision plan

The Financial Services Regulatory Authority of Ontario (FSRA) is an independent regulatory agency established to improve consumer protection in Ontario. FSRA promotes high standards of business conduct by regulating financial services sectors, including the Financial Planners and Financial Advisors sector.

For 2024-2025, FSRA’s supervision approach will focus on:

• conducting thematic reviews of approved credentialing bodies
• raising awareness about the title protection framework among FSRA’s Life and Health Insurance sector

What this means for industry and consumers

FSRA’s supervision plan for 2024-2025 is intended to achieve the following outcomes:

• assess how well approved credentialing bodies are adapting as regulated entities under the Financial Professionals Title Protection Framework
• ensuring that credentialing bodies have processes in place to refer uncredentialed title usage to FSRA once they become aware of an occurrence
• increasing consumer protection and adding value to the framework
• promoting education and awareness about the framework among FSRA’s Life and Health Insurance Sector

The Ontario government introduced the Financial Professionals Title Protection Act, 2019 (“FPTPA”) in 2019 as a consumer protection measure to increase professionalism and confidence for individuals using the Financial Planner or Financial Advisor title in Ontario. The legislation came into force in March 2022.

After the introduction of the FPTPA, FSRA set its focus on approving credentialing bodies and supporting the implementation of the title protection framework. Having established the groundwork of the title protection framework, FSRA engaged with industry and consumer stakeholders to determine supervisory priorities for 2023-2024. Based on these key priorities, FSRA identified a few opportunities for improvement and best practices among the approved credentialing bodies, as detailed in the 2023-2024 Supervision Publication.

FSRA’s 2024-2025 Financial Planners and Financial Advisors Supervision Plan (“Supervision Plan”) builds on the progress made in implementing the framework and promoting consumer interests. As part of this plan, FSRA will review the areas of improvement it previously identified in the 2023-24 Supervision Publication and will also focus on raising awareness about the title protection framework in FSRA’s Life and Health Insurance sector.

Furthermore, the 2024-2025 Supervision Plan addresses the conclusion of the transition period for individuals using the Financial Advisor title. Under the FPTPA, transition provisions were established to assist the industry and their clients to adapt to the new title protection regulations. Following the conclusion of the transition provision for the Financial Advisor title on March 28, 2024, any individual using the Financial Advisor title must hold a FSRA-approved credential. In response, FSRA aims to engage with industry stakeholders to raise awareness about the FPTPA and the implications of uncredentialed Financial Advisor title usage.

As of the date of this publication, FSRA has approved five (5) credentialing bodies and fourteen (14) credentials. The framework ensures that an individual using the Financial Planner or Financial Advisor title:

• has a minimum standard of education
• is actively supervised by an approved credentialing body
• and is subject to a complaints and disciplinary process

Credentialing body thematic reviews

During 2024-2025, FSRA will conduct thematic reviews of approved credentialing bodies. Thematic reviews focus on specific themes across credentialing bodies and provide insights into industry trends, risks, and compliance issues. Furthermore, such reviews serve the public interest by identifying opportunities to promote best practices among credentialing bodies.

FSRA’s focus areas of credentialing body supervision for 2024-2025 are:

1. Reviewing prior year supervisory findings and emerging risks pertinent to each credentialing body
2. Reviewing credentialing body processes to determine if there is a procedure in place to refer uncredentialed title usage to FSRA

Each area of focus is crucial for consumer protection and the promotion of high-quality financial planning and advisory services. At the conclusion of the supervision work, FSRA plans to publish aggregated results and relevant supervision findings, trends, best practices, and areas for improvement identified.

1. Reviewing prior year supervisory findings and emerging risks pertinent to each credentialing body

FSRA intends to review findings or areas of improvement it observed from last year’s credentialing body examinations, and emerging risks relevant to each credentialing body. Reviewing identified areas of improvement reinforces FSRA’s commitment to the promotion of best practices and continuous improvement under the framework. For instance, FSRA recommended that a few credentialing bodies improve credential holder continuing education compliance rates and enhance the accessibility and content of webpages to handle consumer complaints more effectively. FSRA will review the measures implemented by the credentialing bodies in response to these recommendations with the goals of strengthening credential holder oversight and protecting consumers. Additionally, FSRA will review emerging risks pertinent to each credentialing body identified during its supervision activities. This review will provide insights into how credentialing bodies are adapting to the framework and will help FSRA monitor these risks and make recommendations if necessary.

2. Reviewing credentialing body processes to determine if there is a procedure in place to refer uncredentialed title usage to FSRA

FSRA reviews complaints against individuals who use the Financial Planner and Financial Advisor titles without holding an approved credential and those who use titles that would reasonably be confused with the Financial Planner or Financial Advisor titles. FSRA views addressing uncredentialed title use as a shared responsibility among all parties involved and is committed to protecting consumers in Ontario. FSRA aims to ensure credentialing bodies have processes to refer uncredentialed title usage to FSRA for review. This process will uphold the integrity of the title protection framework by ensuring those holding out as a Financial Planner or Advisor are appropriately credentialed, supervised and subject to a complaints and disciplinary process.

FSRA’s education initiative in the Life and Health Insurance sector

The transition period for Financial Advisor title usage in Ontario ended on March 28, 2024. Individuals who wish to use the Financial Advisor title must hold an approved credential from a FSRA-approved credentialing body. FSRA staff performed a preliminary review of internet advertising by financial services professionals and evidence suggests that several individuals are selling life insurance products and referring to themselves as Financial Advisors without holding the necessary FSRA-approved credential. Uncredentialed use of the Financial Advisor title can mislead and harm consumers and erode trust in financial professionals. FSRA aims to launch an educational initiative within the Life and Health Insurance sector to raise awareness about the title protection framework.

FSRA's 2024-2025 supervision plan is designed to enhance consumer protection and promote high-quality financial planning and advisory services. By focusing on areas of improvement FSRA identified among credentialing bodies, processes to refer uncredentialed title usage to FSRA and industry education, FSRA aims to maintain the integrity and quality of financial services provided to consumers.

FSRA will continue to collaborate with licensees and stakeholders in the insurance sector to educate and engage sector participants on uncredentialed title usage under the framework.

FSRA expects approved credentialing bodies and stakeholders to review the 2024-2025 Financial Planners and Financial Advisors Supervision Plan, along with other relevant FSRA publications and resources for the sector.

FSRA welcomes comments from stakeholders on this supervision plan. Your comments will help inform current and future supervision priorities and will increase our understanding of the Financial Planners/Financial Advisors sector.

FSRA maintains key resources related to the Financial Planners/Financial Advisors sector publicly on its website. These resources contain information related to the established regulatory standards that guide FSRA’s supervision efforts for the sector.

Financial Professionals Title Protection – Administration of Applications Guidance

The Administration of Applications Guidance sets out application criteria that approved credentialing bodies have demonstrated in their application to be approved by FSRA. The Administration of Applications Guidance is also a valuable tool for organizations interested in becoming an approved credentialing body and offering a Financial Planner and/or Financial Advisor credential in Ontario.

The application form for approval of a credentialing body and Financial Planner/Financial Advisor credentials is available on FSRA’s website. Interested organizations should contact FSRA for more information on how to apply.

Financial Professionals Title Protection – Supervisory Framework Guidance

The Supervisory Framework Guidance sets out FSRA’s supervision approach under the Financial Professionals Title Protection Act and the provisions of the Financial Professionals Title Protection Rule. The Guidance also explains how FSRA interprets titles that could reasonably be confused with the Financial Planner and Financial Advisor titles.

FSRA also has dedicated webpages with additional information related to the Financial Planners/Financial Advisors sector regulatory framework:

• Financial Planners and Financial Advisors Industry page
• Financial Planners and Financial Advisors Consumer page