In a submission made on Sept. 30 as part of the consultation on the application of Quebec's Act respecting the distribution of financial products and services (Bill 188), the Conseil des professionnels en services financiers (CDPSF) is asking the province's Minister of Finance to delay proposed changes.

The CDPSF is an association of financial services professionals in Quebec, and the first area of concern they address in their submission is the prospect of online sales taking place without an advisor. The CDPSF argues that a licensed representative should be involved in every insurance transaction.

"The CDPSF firmly believes that there would be significant social costs if the government were to eliminate, even partially, the advisory role of the financial services industry," writes CDPSF's CEO Mario Grégoire in his introductory note. The CDPSF recognizes that the Internet is an essential part of doing business, but the group says that this tool makes insurance consumers more vulnerable. In the CDPSF's opinion the role the advisor plays is not just a benefit to the consumer; it acts as a safeguard.

In addition, the CDPSF has commented on easing the regulatory burden and is urging the Minister not to do away with the Chambres, which function as self-regulatory organisations in the province. The group supports the harmonizing of the Mutual Fund Dealers Association (MFDA) rules with Quebec legislation and suggests that it is both possible and desirable that various regulatory frameworks be harmonized across Canada while still respecting provincial distinctions. The CDPSF is also recommending that the role of managing general agents (MGAs) in Quebec be formalized.

Finally, the CDPSF has called for the appointment of an expert committee that would include the Circle of Financial Integrity, an entity which was formed spontaneously when the CDPSF met with 16 MGAs on Sept. 9. What's more, the association would like the discussions concerning possible revisions to Bill 188 to be made public. Ten MGAs have expressed their support for the submission: AFL Financial Group, Financière S_entiel, Peak Financial Group, Financial Horizons Group, Groupe SFGT, Copoloff Insurance Agencies, MICA cabinet de services financiers, Planifax, Pro Vie Insurance, and Union 2005.