Submissions to Government

Final Report of the Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives

The Portfolio Management Association of Canada[1] (“PMAC“), through its Industry, Regulation & Tax Committee, was pleased to have the opportunity to participate in the Ontario government consultation process regarding Financial Advisory and Financial Planning Policy Alternatives (the “Consultation”) in 2016 in connection with which PMAC provided a submission.

PMAC has read the Final Report of the Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives (the “Final Report”) and would like to applaud the work of the Expert Committee as well as the Ontario government for its leadership through this important Consultation. Capitalized terms used but not defined have the same meaning as in the Final Report.

We note with approval the Ontario Government’s commitment to acting on the Final Report as part of the 2017 Ontario Budget. PMAC believes that the implementation of the recommendations in the Final Report can serve to elevate, harmonize and streamline standards for the good of Canadian investors and the health of the financial services industry. We support the Final Report’s focus on a principles-based regulatory foundation for regulators to oversee. This letter sets out PMAC’s comments on the Final Report.

As background, PMAC represents investment management firms registered to do business inCanada as portfolio managers. PMAC members manage investment portfolios for private individuals, foundations, universities and pension plans. Portfolio managers typically have discretionary authority over investments they manage for their clients and have a duty to act in the best interests of their clients: also referred to as a “fiduciary duty”. Individuals registered as portfolio managers have the highest education and experience level in the investment industry: typically, a Chartered Financial Analyst (CFA) designation plus a set period of relevant experience. Under provincial securities regulation, portfolio managers must be registered as advising representatives or associate advising representatives and meet specific proficiency requirements. They are also subject to stringent oversight by securities regulators as well as oversight by a professional standard setting body: the CFA Institute.  Portfolio managers are highly trained professionals, working in a highly regulated industry. We note that some portfolio managers may also have their Certified Financial Planner (CFP) designation. In some portfolio management firms, financial planning services are offered and the firm may hire individuals with a CFP designation, or with an accounting or legal designation, to provide this additional service to clients.

[1] PMAC was established in 1952 and currently represents over 230 investment management firms that manage total assets in excess of $1.4 trillion.  Our mission is to advocate the highest standards of unbiased portfolio management in the interest of the investors served by Members. For more information about PMAC and our mandate, please visit our website at

Read the letter.