Ontarians have been inundated by campaign literature for the upcoming provincial election and electoral system referendum. But it is truly astonishing how little information there is about the electoral system referendum — an issue that goes to the heart of the political system Ontario enjoys and its societal well-being.

In a page that must have been taken from the financial services industry and its regulators, there is, if you read far enough, some fine print that directs people to a Web site for information about the referendum proposal. The Web site has the non-intuitive name of “your big decision” (www.yourbigdecision.ca).

The likelihood of voters accessing and using this information to make reasoned decisions on this fundamental issue is about as remote as the likelihood of inves-tors accessing Web sites to obtain the information they need to make reasoned decisions to invest or to continue to invest in securities.

No matter how you cut it, “access” does not equal “delivery”; and “notice” does not equal “access” or “delivery.” It is, therefore, discouraging to hear so many in the financial services industry objecting to the requirements for delivery of the Fund Facts document contained in the Joint Forum of Financial Market Regulators’ Proposed Framework for Point-of-Sale Disclosure for Mutual Funds and Segregated Funds (NI 81-406).

Instead of focusing on why the requirements won’t work, it would be so much more productive if the focus shifted to how to make them work. This, of course, would mean putting investors’ interests first and making sure they understood the investments they are making before they make the investment.

Investments in mutual funds and segregated funds are long-term investments. It is specious to think that a day or two is going to have that much impact on the investor’s long-term total return. Encouraging investors to think that way smacks of market-timing and speculation rather than investing.

The whole process leading to an investor’s decision to purchase needs to be re-engineered to make sure inves-tors have the information they need to make reasoned investments before they make the investment and throughout the period that they hold the investment. This would go a long way toward reducing the number of investors who are unhappy with the industry and their investment experience. Regulators need to find the backbone to insist on the necessary changes.

One change I mentioned in last month’s column is the need to develop a prototype plain-language foundation document to replace the current simplified prospectus and annual information form. I also mentioned the need to develop a prototype plain-language annual report, among other documents investors receive.

I have given some more thought to this and to the need to streamline the disclosure process. My suggestion is to replace the current simplified prospectus, annual information form and annual report with one integrated plain-language document — a Fund Information Form — that would contain all the information that investors need to make a reasoned decision. Although the proposed Fund Facts document would form part of the Fund Information Form and would be cross-referenced to the more detailed information contained in the Fund Information Form, it could also be delivered separately.

The integration of initial disclosure with continuous disclosure for reporting issuers is something that regulators and the industry contemplated many years ago when the requirements for management discussion and analysis were first introduced. Such integration would work well in the case of investment funds and would eliminate a lot of the duplication that now exists. It would simplify life for investors and financial advisors alike. And it would assist the fund industry in meeting its disclosure obligations.

This idea is a logical extension of the Joint Forum’s Fund Facts proposal and would go a long way in meeting concerns that the Fund Facts document doesn’t provide inves-tors with the information to make reasoned investment decisions. It’s an idea worth thinking about. IE