IIAC RESPONDS TO FSRA TITLING REQUIREMENTS FOR FINANCIAL ADVISORS AND FINANCIAL PLANNERS
The IIAC submitted a comment letter to the Financial Services Regulatory Authority (FSRA), responding to its second version of the Financial Professionals Title Protection Rule and Application Guidance.
FSRA has not yet determined exemption provisions, although the IIAC continues to argue that individuals registered with IIROC and the MFDA should be exempt from the requirements of the framework.
Through new Guidance, FSRA has clarified somewhat the titles that could reasonably be confused with the Financial Planner (FP) or Financial Advisor (FA) titles. However, this list of titles does not include “investment advisor”, “wealth advisor” or securities advisor”, for example. The IIAC requested that these titles be included in FSRA’s non-exhaustive list for greater clarity. FSRA has stated that issues pertaining to titles will be complaints-based, but the IIAC stressed the industry needs certainty the titles it uses are either deemed confusing or not.
Our comment letter also discusses the disclosure of credentials, continuing to state that it should not be a mandatory provision. FSRA has now proposed that a Credentialing Bodies’ (CB) code of ethics and professional standards include policies and standards with respect to the disclosure of credentials and suggests the disclosure could be added to business cards, marketing material, letterhead, and contracts with clients. FSRA has also stated that credential holders would have to confirm with the CB that clients have been provided with the appropriate disclosure of credentials. We argue this would create an unnecessary regulatory burden for market participants and increase the costs for member firms as well as CBs that would now have to monitor compliance.