We recognize CIRO’s objective of harmonizing the rules applicable to Investment Dealers (IDs) and Mutual Fund Dealers (MFDs) in an effort to level the playing field for advisor compensation. Fundamentally, we believe that regulatory changes should not be rushed and need to be implemented properly to minimize investor protection risk and regulatory arbitrage. It’s also critical to fully analyze each option being proposed in the context of impact and changes needed to relevant tax, corporate and/or securities laws.
KEY RECOMMENDATIONS
- Determine whether the use of personal corporations in the investment sector complies with relevant corporate, securities and taxation laws.
- If the use of personal corporations is to be permitted, harmonize their use across all registration categories and between provinces to minimize regulatory arbitrage.
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