Title protection called a bureaucracy created to justify too many regulators

The Investment Industry Association of Canada (IIAC), a national association of investment firms which manufacture and distribute wealth management and advisory services, says title protection legislation results in unnecessary administration and duplication of regulatory oversight.

“Investors need financial advice and planning, not bureaucracy created to justify too many regulators in the same space,” they write in a submission to the government of Manitoba, which is considering its own version of legislation created by Ontario, Quebec, Saskatchewan and New Brunswick.

“Individuals who are registered with CIRO (Canadian Investment Regulatory Organization), the Manitoba Securities Commission, and the balance of the CSA (Canadian Securities Administrators), to provide investment advice, possess the appropriate qualifications to call themselves financial advisors or financial planners,” the submission states. “The oversight that is already being provided by these regulators and their corresponding Securities Acts, National Instruments, rules, policies and guidance should not be duplicated. Further government action is neither necessary, proportionate, nor in the public interest.” 

They further point out that investors have received financial planning advice from those registered and supervised by the Manitoba Securities Commission, CSA members and CIRO for years. “These regulators review credentials, titles and conduct,” they write.

The submission also points out that the regulators have well-established governance structures, strong public interest mandates, the necessary skills, established enforcement processes, resources, policies and procedures to administer and monitor compliance. They further point out that National Instrument 31-103 already sets our registration requirements across Canada.

“For securities, regulatory co-ordination has been achieved through the CSA which oversees CIRO, as a national regulator and approves National Instruments. Regulatory regimes adopted in Ontario and proposed in Saskatchewan and New Brunswick run contrary to regulatory coordination.”