IAP Notice: IAP Submits Cost Disclosure and Performance Reporting Comment Letter

Ontario Securities

20 Queen St. W.
Box 55, Suite 1900
Toronto, ON M5H 3S8

Commission des valeurs mobilières de l'Ontario


September 26, 2011


IAP Submits Cost Disclosure and Performance Reporting Comment Letter


TORONTO – The OSC Investor Advisory Panel has submitted its comment letter to the Ontario Securities Commission regarding the proposed amendments to National Instrument 31-103 Cost Disclosure and Performance Reporting.

The Panel gave a wholehearted endorsement to the proposed initiative and indicated their overall support. “We are pleased that the CSA is taking this step. The proposed changes are necessary amendments to the disclosure landscape to help redress the information imbalance between financial advisors and their clients, especially in terms of information that investors receive from their dealers. However, we believe that some additional changes in the law are necessary and our submission speaks to these changes.” said Professor Anita Anand, Chair of the Investor Advisory Panel.

The submission covered significant terrain and consisted of the following main points:

  • Investors should receive annual statements disclosing costs in BOTH dollar and percentage terms.
  • The format for performance report should be standardized. Combining the cost and performance reports would increase the impact of these reports – and the likelihood that they would be read by investors.
  • Benchmarks are important and useful but require additional study.
  • CSA should explore imposing significant penalties for non-compliance.
  • The proposal should be implemented in one year rather than two.

The Panel expressed its view that speedy implementation of the proposed amendments are long overdue and serve to benefit investor interests.

The Investor Advisory Panel was created in 2010 as an independent body to contribute an investor perspective to the OSC’s rule and policy making process. The comment letter and additional information about the Investor Advisory Panel are available on the OSC website at www.osc.gov.on.ca.





For Media Inquiries: Anita Anand
Chair, Investor Advisory Panel
c/o Allan Krystie, Senior Administrator,
Investor Advisory Panel
For Investor Inquiries: Allan Krystie
Senior Administrator
Investor Advisory Panel
[email protected]