The Portfolio Management Association of Canada1 (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the Financial and Consumer Services Commission of New Brunswick (FCNB)’s consultation notice – Title Protection 2021 (the Consultation). Capitalized terms used but not defined in this submission shall have the meaning given to such terms in the Consultation. We appreciate that FCNB is looking at ways to create a nationally harmonized framework of standards for financial planners and that, as a result, New Brunswick is considering whether to closely reflect Ontario’s proposed legislation and regulations on this topic. PMAC has made several submissions to the Financial Services Regulatory Authority of Ontario (FSRA) on the regulation of the Financial Planner (FP) and Financial Advisor (FA) titles, and we believe our comments will be relevant your own Consultation. Rather than repeat them here, we refer you to our submissions to FSRA dated November 12, 2020 and July 5, 2021. Additionally, we refer you to our submission dated October 1, 2021 to the Financial and Consumer Affairs Authority of Saskatchewan (FCAA) where we respond to the FCAA’s proposals to closely follow Ontario in regulating the FA and FP titles. In these comment letters, PMAC raised serious concerns about certain details of FSRA’s Rules and Guidance, including with respect to the regulation of the Financial Advisor (FA) title. We have set out our key recommendations below, which we believe are equally applicable to the FCNB Consultation.
Read the full submission here.