









Canadian Securities Administration
In April 2016, the Canadian securities administrators (CSA) published a consultation paper that sets out a series of proposed “target reforms” that aim to address regulators ongoing concerns about client/advisor relationships. Regulators continue to be concerned about the large information gap that exists between most clients and their advisors, among other things.
Indeed, several recent surveys have revealed that 40% - 60% of Canadian investors are unaware of how much they pay for investment advice;
many believe they pay no fees at all. Regulators also are worried that clients lean too heavily on their advisors for financial advice and that, despite that reliance, clients are not getting value for their money.
Regulators are concerned that conflicts of interest, rooted in the compensation system are too pervasive and not well managed by advisors or their firms.
Source: (Investment Executive by James Langton)
Regulators call the new rules CRM 2 – (Client Relationship Model). Under CRM2 investment firms have to provide personalized accounting of investment returns and the dollar amount of fees received in connection with your account. Most investors will see upgrades in fee and performance disclosure starting mid-January 2017 that cover calendar 2016.
CRM2 provides disclosure of the cost of advice, but NOT
the total cost of an investment product. Amazingly, CRM2 only requires partial disclosure!!!!!
You will NOT see what your advisor makes nor will you see investment fees. The
reporting rules do not require disclosure of other costs of owning investment funds - such as management fees, fund operating costs, redemption fees and short-term trading fees. The cost of advice is what CRM2 covers, NOT the cost of the investment products you own.
Imagine you own mutual funds with a management expense ratio of 2.2 per cent. Trailing commissions would account for 1 percentage point of the MER, which you’ll see as a dollar amount under CRM2. The dollar cost of the remaining 1.2 points of MER will not be shown. If you have a fee-based account, you will be shown the dollar amount of fees paid to your investment firm, but not the fees associated with the products you own. Confused? So are most investors!
In the study, commissioned by University of Calgary’s school of Public policy and released earlier this year, the study’s author, Pierre Lortie, observed that comparability is necessary to promote market efficiency - which is where CRM2 disclosures still fall short. “The new set of cost-and performance-reporting requirements introduced by the [Canadian securities administrators (CSA)] - generally known in the industry as CRM2 - is lacking in this regard,” the report states. “The charges and compensation information to be provided to individual clients is limited to the amount paid directly or indirectly by an investor to the dealer firm. The report does not provide a breakdown of how much is paid to the advisor or for the different services rendered by the firm, it does not include the amount paid by the investor to the investment manager of the mutual funds or ETF’s in his or her portfolio, thus blurring transparency on total fees, nor does it address industry-wide transparency.”
Source: Investment Executive by Jim Middlemiss
Ottawa. We Have a Problem!
Canadian regulators need to get on the side of consumers and investors to mandate full disclosure and transparency. We deserve better. The lack of full disclosure does not end there. It’s actually worse with other financial products that are not subject to the CRM2 rules!!
Some Products are EXEMPT from the New Rules!
CRM2, an initiative of the Canadian Securities Administrators (CSA), the Investment Industry Regulatory Organization of Canada and the Mutual Fund Dealers Association of Canada, covers only mutual funds and securities.
Products that fall under the jurisdiction of other regulatory bodies, such as insurance, PPNs, certain real estate and mortgage investment products, and guaranteed investment certificates, are therefore not subject to CRM2. For example an insurance investment product called a segregated fund is very similar to a mutual fund but is classified as an insurance product and, therefore, is not subject to the new disclosure requirements. With fees and commissions for mutual funds set to be outlined in far greater detail compared with those for segregated funds, it could become difficult for clients to make accurate comparisons between these types of products.
There has been some speculation within the investment industry that dual-licensed advisors may change their focus to selling segregated funds rather than mutual funds and securities, which require enhanced reporting of performance and costs.
Source: Investment Executive by Jade Hemeon
Due to the insurance contract element, management-expense ratios on insurance based products can be an additional 50 to 150 basis points (.5 to 1.5%) on top of the cost of a mutual fund. (This equates to a 2.9% to 3.9% Management Expense Ratio!!)
Get Educated and Vote with Your Wallet
An email from the Ontario Securities Commission also stated that the CSA is preparing new requirements that it hopes to publish later this year. If approved, it will provide more detail to clients about the cost of investing.
Even if those changes come, say Banerjee and Buffel, Canadians need to educate themselves to ensure they get all the information they need from banks. “If you understand the language that’s being spoken at you, you need to educate yourself and ask good questions,” Buffel advised. “Sometimes, the financial advisors are a little uncomfortable about those questions because they’re opening up and being more transparent about the fees, but that’s what a good consumer asks for.”
Banerjee also encourages unhappy bank customers to “vote with their wallets.”
“Canadians love to gripe about fees, but ultimately, don’t do anything about it,” he says.
The Fox in the Hen House- Big Banks and their Corporate Finance Departments
Canadian banks have large internal corporate finance departments (“investment bankers”) whose job it is to help Canadian businesses to create new securities (e.g. a new preferred share issue). They often create fancy “manufactured” products (e.g. a split-share corporation) and may take private companies public through initial public offerings.
These products may be created by one department of the bank and then sold to the public through the brokerage arm of the same bank, meaning that the level of objectivity and independence of advisor and bank is certainly suspect.
To avoid this potential trap, hold your accounts with a brokerage that does not have its own corporate finance group looking to distribute their products through their own sales force.
Product Ties That Bind…
A lesser discussed topic is the bank’s desire to keep a client for the long term. This means making it difficult to leave by tying the client to multiple products and services so that it is difficult or costly to leave.
One element of this approach is the use of proprietary products. Proprietary products created by any institution cannot be transferred to another institution, meaning you will have to sell the asset if you leave, potentially triggering a costly taxable event.
Proprietary products by any institution can include non-transferrable GICs, private pooled funds, wrap programs and others. These are NOT fringe products. They are mainstream products that many, many Canadians own. Yet, it is unlikely that you were told about the downsides of these products when you bought them. Be wary of proprietary products, regardless of how attractive they may seem.
You might be asking yourself, “Where do I find the right Financial Consultant near me who charges a flat fee and will treat me fairly?” “Where can I find an advisor who can create an Integrated Aligned Overarching Strategy?” or “Where can I find an advisor who will only invest my money in proven passive investments? We suggest that you interview several. You’ll quickly learn that there are very few who are fiduciaries, believe in passive investing and have a process to create an Integrated Aligned Overarching Strategy. When you do find the right advisor, you’ll be able to relax in the knowledge that you are in the right hands and that your financial future is secure. Feel free to reach out to me with your questions. I’m committed to investor education.
Dean Kendall is a Financial Organizer in Calgary, handling all of the financial affairs for a select group of clients who value unbiased quality advice for one simple flat fee.
His book - Stop Paying Hidden Investment Fees! Click here for more information https://www.ideallifeexperience.com/Stop-Paying-Hidden-Investment-Fees
Newest book - Becoming The Champion of Your Dreams: How to Set and Achieve Your Most Important Goals Click here for more information. https://www.ideallifeexperience.com/Becoming-the-Champion-of-Your-Dreams
In addition, Dean is a 3X Canadian National # 1 Amateur, a 5X Canadian National #1 Professional BMX rider, downhill mountain biker and an avid snowboarder. He is an expert at winning. Let him show you how to win the money game. You can reach Dean at dean@ideal-life-experience.ca or Phone 403-543 -7226
©Copyright 2008 – 2022 by Dean Kendall. All rights reserved. 403-543-7226
dean@ideal-life-experience.ca