Submission to Securities Commissions | Proposed Amendments to National Instrument 81-105 Mutual Fund Sales Practices and Related Consequential Amendments

We participated in the OSC’s September 2017 roundtable discussion on alternatives to eliminating embedded commissions. Much of the industry participation that day was seemingly aimed at protecting themselves with little regard for clients. This must change. In particular, we urged the broader industry – particularly dealers, dealing representatives, and mutual fund manufacturers – to focus on how each of them would want to be treated as clients of the industry; and focus efforts on creating feasible ways of delivering what clients need and deserve.

We also support the OSC in pushing back against the Ontario Minister of Finance. The Minister’s statement opposing these proposals appear to be motivated by politics; not by investor protection objectives.


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