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September 2025 Advocacy Newsletter
Summary:
We hope everyone is settling into the September pace of things – we’ve certainly been busy. This month, we’ve worked with the CAC to prepare and submit four responsive comment letters to Canadian regulators that focus mostly on regulatory harmonization cross-border (on short selling into offerings), between rulebooks (disgorgement provisions in the mutual fund dealer rulebook), and between different types of fundamentally conflicted fee models (banning chargebacks for investment funds).
The final responsive comment letter this month focused on the CSA’s proposal to give OBSI binding authority. The CAC was broadly supportive of the direction of policy, but noted that an overbuilt regulatory oversight mechanism would carry meaningful costs, and questioned whether the governance and oversight framework proposed was fit-for-purpose. It also opined on a preferred approach for 2nd-reviewing larger disputed amounts through OBSI staff with independence from the initial review, rather than external adjudicators, due primarily to cost concerns relative to the investor need, and an overwrought concern about adjudicative independence given a lack of foundational conflicts. As this policy file hopefully draws to an initial conclusion at the CSA, our efforts will hopefully prove to have been influential in seeing retail investor redress options improve through OBSI.
Outside of responsive advocacy publications, we remain engaged on entrepreneurship, competition, and innovation with multiple governments and regulators across Canada. With rapid regulatory evolution in the United States underway, it underscores the need for Canada to move forward boldly and quickly on charting its own course for the investment and financial services sector within the context of renewed concerns about economic sovereignty. We remain concerned that our lack of regulatory harmonization will make it difficult to be as dynamic and responsive in Canada as some of these changes abroad should demand. This underpinned recent commentary to the Canadian government in our pre-budget submission, and will be the focus of upcoming meetings with both federal and provincial government officials, and with Canadian regulators. We need to work harder to meet this moment by being dynamic, harmonized, and ambitious.
I’ll also be carrying this message to the stage at the upcoming annual Alberta Securities Commission Connect conference in Calgary on October 23rd. I think we need to encourage more genuine conversations about the degree to which financial innovation leads to (in my view) obvious questions of policy and regulatory sovereignty, and how our Canadian institutions (government, regulatory, investment, and financial-sector businesses) need to rapidly adapt to be relevant in this emerging reality. I’m looking forward to the panel and the opportunity to connect with important Alberta-based stakeholders.
Heading into October, both our proactive outreach agenda and responsive commentary plans remain robust, as we await the Supreme Court’s decision in Lundin v. Markowich, and continue to engage on proficiency evolution in the Canadian industry, noting particularly Fitch Learning’s recent purchase of the legacy Canadian Securities Institute business from Moody’s.
We will again highlight that effective January 1, 2026, CIRO’s new proficiency model takes effect, with significant new recognition for CFA Program in the form of exam waivers. CFA charterholders or recent passers of the Level 1 exam will be able to avail themselves of a waiver for the introductory CSIE exam, and either of the qualifying ‘segment’ exams – Retail or Institutional. This process runs through the CIRO dealer member firm at the time of registration, so there’s no action to take on an individual level to qualify. See CIRO’s proficiency website for more details on the new model, and expect to see more awareness-building soon on what this means for CFA charterholders and current and potential CFA candidates from our channels.
Michael Thom, CFA
Managing Director
CFA Societies Canada