Re: Fund Facts still seriously flawed (October 2011 issue)<\/strong><\/a><\/p>\n \tI read with interest the guest column written by Ermanno Pascutto and Marian Passmore at FAIR Canada.<\/p>\n
\tWe would be the first to suggest the point-of-sale initiative, as it stands, is not the ideal solution. However, the evident frustration and criticism of the POS initiative in the column is unjustified, conveniently avoiding critical information, and failing to recognize the well-meaning efforts of the regulators, the securities industry and the investing public to strike the right balance between investor protection and a cost-efficient transaction process.<\/p>\n
\tThe lengthy rule-making process reflects efforts to consult widely with market participants to find the right abbreviated disclosure for Fund Facts, particularly in the context of extensive reforms to the disclosure and conduct in the financial advisory business, as well as an effective mechanism to deliver timely disclosure before executing a trade.<\/p>\n
\tThe column neglects to mention the reforms supplementing disclosure in the Fund Facts document, such as conflict-of-interest disclosure mandated in National Instrument 31-103 and the client relationship model, or the approach adopted by the securities industry to provide email communication to clients with “hot links” to relevant disclosure information before a mutual fund is purchased. The article gives the impression the Stage 2 disclosure requirement is the final rather than an interim step until the issues related to POS delivery prior to a mutual fund purchase have been resolved.<\/p>\n
\tWhile [we have] proposed the Securities and Exchange Commission approach that “access to disclosure (on a designated website) equals delivery,” the Canadian Securities Administrators seeks a more fulsome solution.<\/p>\n
\tThe column, written with a rather selective perspective on the rule-making process, is unfair to well-intentioned efforts at reform, and undermines the very investor confidence the rule framework attempts to bolster.<\/p>\n
\tIan Russell, president and CEO,<\/em><\/p>\n \tInvestment Industry Association of Canada<\/em><\/p>\n \tToronto<\/em><\/p>\n","protected":false},"excerpt":{"rendered":"James Langton’s article on the new investor advisory panel engaged in unfounded criticisms of the investor advisory committee<\/p>\n","protected":false},"author":4,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":[],"categories":[3013,3014],"tags":[2515,2788,2473],"yst_prominent_words":[],"acf":[],"_links":{"self":[{"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/posts\/333489"}],"collection":[{"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/users\/4"}],"replies":[{"embeddable":true,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/comments?post=333489"}],"version-history":[{"count":1,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/posts\/333489\/revisions"}],"predecessor-version":[{"id":370517,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/posts\/333489\/revisions\/370517"}],"wp:attachment":[{"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/media?parent=333489"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/categories?post=333489"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/tags?post=333489"},{"taxonomy":"yst_prominent_words","embeddable":true,"href":"https:\/\/www.investmentexecutive.com\/wp-json\/wp\/v2\/yst_prominent_words?post=333489"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}