The task force struck by the Investment Dealers Association of Canada has handed down a report proposing a series of good, solid reform recommendations. But there are also some critical omissions.

The background research commissioned by the task force proposes some important ideas that didn’t make it onto the final list of 65 recommendations.

Notably, a paper from professors Mary Condon and Poonam Puri makes a number of suggestions that would improve the functioning of the retail market by closing the information gap between the industry and investors. It calls for greater up-front and ongoing fee disclosure, enhanced compensation disclosure and the disclosure to clients of proven complaints of unsuitable or abusive sales practices. The paper also recommends higher proficiency requirements and that regulators take a harder line against persistently abusive brokers.

Although the IDA report has much to say about improving investors’ access to restitution — and rightly so — it would be better for all concerned if cases requiring restitution could be avoided altogether. And more honest, meaningful disclosure about fees and disciplinary histories would be much more useful in this regard than the fancy video-embedded prospectuses the report contemplates.

Moreover, there are a couple of glaring gaps in the task force’s otherwise impressive report — although, to its credit, it acknowledges both of them.

Although the report recommends that regulators undertake stringent cost/benefit analysis for any rules they propose to adopt, it doesn’t subject its own series of dramatic reform proposals to similar scrutiny. The task force acknowledges this fact in the report, but this absence still undermines the whole exercise.

Second, the report tries to avoid questions of the appropriate structure for securities regulation. Again, the report admits this, noting that the IDA didn’t want to rehash an exhaustively discussed topic.

However, if this report is to serve as a call to action rather than merely an intellectual exercise, the overriding structural issues must be dealt with, too.