The Canadian Advocacy Council1for Canadian CFA Institute2Societies (the CAC) appreciates the opportunity to comment on the CSA’s Discussion Paper and Request for Comment 81-407 –Mutual Fund Fees. We believe that current mutual fund fee structures raise sufficient investor protection concerns such that additional regulatory action is required at this time.
Overview of the Council’s Comments:
We note that such a change would require adequate advance notice such that advisors would have the opportunity to discuss all the ramifications with their clients. In particular, clients who rely on distributions from their portfolios for income may require some time to adjust to any fee payments which would visibly reduce that stream of income. It will be important to present the fee in dollar terms so that it can be easily understood by all clients.