The CAC does not believe at this time that banning third-party commissions, as is the case in certain international jurisdictions, is necessary. However, the CAC wishes to stress that regardless of the account type that is ultimately deemed suitable for a particular client, the advice given by a registered representative to meet a client’s goals should be the same. We believe that the draft guidance note should emphasize that registered representatives should act in a manner consistent with a fiduciary obligation to act in the best interests of their clients.
Overview of the Council’s Comments:
The CAC would like to see well-documented disclosure of all embedded fees in both commission-based and fee-based accounts, with a clear delineation of fees that have been included, fees that are excluded, and any adjustments that have been made.