IFIC Makes Submission to CSA on Total Cost Reporting Consultation
July 27, 2022 (Toronto) – The Investment Funds Institute of Canada (IFIC) today made its submission to the Canadian Securities Administrators (CSA) in response to the CSA and Canadian Council of Insurance Regulators Joint Notice and Request for Comment related to Total Cost Reporting for Investment Funds and Segregated Funds.
IFIC prefaced its submission by reiterating that it has supported expanded cost reporting to investors since 2017, shortly after the implementation of CRM2. This position was also outlined in IFIC’s 2018 submission to the Mutual Fund Dealers Association of Canada.
“Providing investors with more complete cost information related to the investment funds they hold is the ultimate goal for regulators and the industry,” said Paul Bourque, President and CEO, IFIC. “We believe the best way to both accomplish this goal and reduce the risk of investor confusion is to include fund expenses in the annual report of costs and performance and to only include investor-specific information in quarterly or monthly account statements.”
In its submission, IFIC recommended against the proposed inclusion of a fund expense ratio (FER) in quarterly client account statements. Because the FER would not be individualized, not in dollar terms, and not in the context of appropriate performance information, it could be misleading to investors.
IFIC also recommended that the implementation timeline be extended to 3.5 years from the date of final rule, which is in keeping with the time provided to implement CRM2. “We are concerned that the proposed transition period will not provide sufficient time to ensure successful implementation and look forward to working with the CSA to identify and overcome operational and technical barriers,” added Bourque.
The submission references third-party research by PricewaterhouseCoopers LLP. The full research report is included in the submission.
About IFIC
The Investment Funds Institute of Canada is the voice of Canada’s investment funds industry. IFIC brings together approximately 150 organizations, including fund managers, dealers, professional and back-office service providers, to strengthen the integrity of the investment funds industry, foster public confidence in investment funds, and enable investors to achieve good outcomes. By connecting savers to Canada’s economy, our industry contributes significantly to Canadian economic growth and job creation.
For more information, please contact:
Pira Kumarasamy
Senior Manager, Communications and Public Affairs
pkumarasamy@sima-amvi.ca
416-309-2317
