Re: “Trust requires point-of-sale disclosure,” by James Langton (IE, October 2008).

Your editorial illustrates a total misunderstanding of the securities industry position on the proposed point-of-sale framework and, despite an evident feckless disregard to understand our position and reasons for it, makes the unfair and wholly inappropriate accusation the industry “resists simple efforts to put clients first.” Nothing could be further from the truth.

The industry recognizes the importance of effective mutual fund disclosure and has been strongly supportive of the mandated two-page “Fund Facts” document that summarizes key features of a mutual fund.

However, the industry has continually advocated the need for a practical disclosure regime that doesn’t interfere with instantly executed intra-day trades in fund shares.

Investors buy and sell large volumes of these shares within a trading day in anticipation of the end-of-day price. The requirement to deliver the Fund Facts document before a security purchase interferes with rapid execution of client transactions.

The answer is to adopt the SEC approach “access equals delivery.” If advisors provide clients with easy access to disclosure through designated Web sites, e-mail and other channels, in advance of related fund purchases, then disclosure needs are met and trading is not disrupted.

Your editorial page risks credibility if you insist on trumpeting damaging and unfounded allegations without taking the trouble to understand the facts.

Ian C.W. Russell FCSI

President & Chief Executive Officer Investment Industry Association of Canada



The mutual fund industry is a retail service industry. Mutual fund managers and dealers are driven by the needs and interests of their clients — individual retail investors. Ignoring this reality would not be a successful strategy for firms in our industry.

I am therefore completely surprised by, and disagree with, the assertion of the IE editorial that the industry has a position that does not put clients first. Individual investors themselves tell us otherwise.

In third-party research conducted annually by POLLARA Inc., investors continually report high levels of reliance and satisfaction with advisors in the purchase of mutual funds and with the range of benefits of the product itself.

Your editorial claims delays in processing a mutual fund transaction are not of concern to investors. This is not the case. In times of high market volatility, investors have increased demand for immediate execution of their trades.

The higher processing loads and cumbersome delivery requirements of this rule will interrupt the sales process, and in some cases will delay transactions from happening at the time of the investor’s choosing.

Meanwhile, the ability to transact in a timely manner will continue to be available in other products. Dissatisfied investors will ultimately turn to these other products, including stocks, bonds, ETFs, hedge funds, separately managed accounts and wraps, all of which can be more readily and easily purchased without pre-sale disclosure. Some of these products have risk characteristics and embedded compensation structures that are more complex and opaque to the investor than those of mutual funds.

Costs will rise — both in terms of distribution and compliance, which will inevitably drive up fund MERs and lower returns to investors.

We heartily agree that our industry — and financial services in general — is built on investor trust in financial markets. We believe strongly, therefore, in enhanced disclosure for mutual funds that will be more accessible, readable, and easily understood by investors than is provided for currently.

The two-page format of the Joint Forum’s proposal is a significant step in this direction, and we applaud its development. What we do not support are cumbersome delivery requirements narrowly focused on mutual and segregated funds to the exclusion of other investment products.

Joanne De Laurentiis

President & CEO

The Investment Funds Institute of Canada October 2, 2008



Re: Money Planner — Protecting your assets, (IE 2008-2009).

As a Chartered Accountant and Certified Financial Planner for small and medium sized enterprises, professionals and individual taxpayers; I wish to compliment you and your contributors for the recent publication of Money Planner – Protecting your assets . I have found the recommended strategies for Canadian families extremely helpful and well presented.

Unfortunately, I have found (as many others) that a great majority of Canadians cringe from fear when confronted with financial planning. They do not attend complimentary seminars, they do not peruse financial reports issued by public corporations and usually dump them in waste bins.

@page_break@I have also found that the closer clients get to retirement, the more they worry, that likely they will run out of money or that the current volatility of the capital markets will in time ravage their resources. They also want to maintain (why not) in their retirement years, the approximate standard of living enjoyed in their working years.

Government care is currently minimal: as the population ages, it’s resources will be spread even thinner in our present economy. No financial plan is complete unless it addresses long-term care. Retirement planning demands mental energy and time in making needed decisions. Your periodical publication, together with the advisors, are the best assurance that retirement planning is tailored to Canadian needs. Congratulations and keep publishing vital resourceful information.

Albert L Stat C.A., Toronto