BCN 2013/01 Notice and Request for Comment –Proposed Revocation of BC Instrument 32-513 Registration Exemption for Trades in Connection with Certain Prospectus-Exempt Distributions andBC Instrument 32-517 Exemption from Dealer Registration Requirement for Trades in Securities of Mortgage Investment Entities(the “Notice”)

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BCN 2013/01 Notice and Request for Comment –Proposed Revocation of BC Instrument 32-513 Registration Exemption for Trades in Connection with Certain Prospectus-Exempt Distributions andBC Instrument 32-517 Exemption from Dealer Registration Requirement for Trades in Securities of Mortgage Investment Entities(the “Notice”)

Letter Summary:

We support the CSA initiative that is currently underway with respect to potentially imposing a fiduciary duty on registrants, and strongly support imposing a statutory best interest standard on registered dealers providing advice to clients, including advice on privately placed securities. Such a standard would help to ensure that an investment in privately placed securities is in fact in a client’s best interests We also wish to note that the implementation of the proposals to remove the dealer registration exemptions would help harmonize the dealer registration requirements across Canada, which would assist investors in understanding what they can expect from their financial advisors.

Overview of the Council’s Comments:

The Canadian Advocacy Council1for Canadian CFA Institute2Societies (the CAC) appreciates the opportunity to comment on the Notice. The CAC generally supports the proposed removal of the two dealer registration exemptions set out in the Notice as aninvestor protection measure.