The requirement concerning the pre-sale delivery of Fund Facts disclosure documents could be finalized as early as December, according to Sian Burgess, senior vice president of fund oversight at Toronto-based Fidelity Investments Canada ULC, along with a longer than expected transition period.

Burgess, who is also vice chairwoman of the Investment Funds Institute of Canada’s (IFIC) board of directors, spoke at the 12th annual Institute of Advanced Financial Planners (IAFP) Symposium in Calgary on Tuesday.

“If [regulators] really do publish in December,” said Burgess, “18 months from then you will be required to give Fund Facts to your clients before the final sale.”

When the Canadian Securities Administrators (CSA) proposed the regulatory reform in March 2014, they initially suggested a one-year transition period to deliver the documents before the sale of a mutual fund. The industry, on the other hand, asked for a two-year transition period, said Burgess.

The new regulation will also provide a less time-consuming process for the delivery of Fund Facts than was first proposed five years ago. Originally, regulators said they wanted clients to acknowledge in writing that they had received the Fund Facts document. Now, Burgess said the rules allow clients to use other means to confirm that they received the documents and they’ve had an opportunity to read them.

“[It’s] still another thing you’ll have to add to all those things you have to do before a trade,” said Burgess, “but not as bad as we used to think.”

Clients will be able to confirm receipt of the documents through an email, by clicking on a link or through verbal communication. Burgess warned however that advisors must be careful to take detailed notes in cases where clients acknowledge receipt of the documents verbally.