January 2023 Advocacy Newsletter
It’s hard to believe 2023 is now well underway. 2023 in the Gregorian calendar is designated the Year of the Rabbit. As the Rabbit is a symbol of longevity, peace, and prosperity in Chinese culture, the start of the year is thought to usher in a welcomed respite from the volatility and unpredictability of the Year of the Tiger, which preceded it. This hopefully means we have seen the last interest rate hike, and that inflation and the cost of living will come down in 2023.
It’s also a time for caution as the Rabbit is also associated with trustfulness. Trust underpins our capital markets – trust in ESG, Indigenous reconciliation, and other financial reporting; trust in financial professionals; trust in the regulators and regulatory processes; trust that investors have a system that affords them protections. The Council continues to advocate for regulations that support these trusts.
Our recent letters touched on various trusts. In our response to the OSC’s Statement of Priorities we highlighted that we were disappointed at the lack of new investor protection initiatives and the seeming lack of progress on existing initiatives (e.g., the provision of binding authority to OBSI). The Council queried why the priorities in the Consultation were so heavily weighted toward financial innovation (which could increase systemic risk), rather than innovation aimed at protecting investors (which is often a systemic risk reducer). As related to climate disclosures we noted that rather than pause work on climate disclosure standards to consider developments in other jurisdictions, we would prefer that the CSA proceed with its proposed improvements and update these standards as international practices. Our complete summary and link to the respective consultation letter is included below.
The Council also responded to IIROC’s Consultation Paper (Phase III) — Competency Profiles for Supervisors, Traders, Associate Portfolio Managers and Portfolio Managers . We firmly support initiatives to examine and improve registrant proficiency. While the proposed competency profiles are generally comprehensive, we noted potential gaps for further consideration in the approach, such as consideration of sustainability and ESG reporting by issuers and approaches in investing, Indigenous reconciliation, rights and title, DEI (diversity, equity and inclusion) and vulnerable clients. We suggested reviewing the competencies against requirements for the types of investors who are serviced by these registration categories, from the ‘bottom up’, as opposed to the ‘top down’ segmentation of registrant categories. Such a review would accord with securities regulators’ investor protection mandate. Our complete summary and link to the respective consultation letter is included below.
The work the Council does to build and uphold trust in our Canadian financial system would not be possible without our dedicated volunteers. I would also like to thank our volunteers for their continued service and extend a warm welcome to the newest member of CAC, Ijeoma Madueke, CFA.