:Canadian Securities Administrators Consultation Paper 33-403: The Standard of Conduct for Advisers and Dealers: Exploring the Appropriateness of Introducing a Statutory Best Interest Duty When Advice is Provided to Retail Clients (the “Consultation Paper”)

February 21, 2013

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Canadian Securities Administrators Consultation Paper 33-403: The Standard of Conduct for Advisers and Dealers: Exploring the Appropriateness of Introducing a Statutory Best Interest Duty When Advice is Provided to Retail Clients (the “Consultation Paper”)

Letter Summary:

Regular account information. Members and candidates with control of client assets should submit to each client, at least quarterly, an itemized statement showing the funds and securities in the custody or possession of the member or candidate plus all debits, credits, and transactions that occurred during the period; should disclose to the client where the assets are to be maintained, as well as where or when they are moved; and should separate the client’s assets from any other party’s assets, including the member’s or candidate’s own assets.

Overview of the Council’s Comments:

As a general note, we believe it is very important that the CSA requires registrants to provide advice to clients to abide by the best interests standard. As CFA charter holders, we have agreed to uphold the Code of Ethics, which requires us to put the best interest of our clients ahead of our own. We believe that retail clients, the investment industry and society as a whole would benefit if all professionals offering investment advice were held to this high standard