We are broadly supportive of the initiative of the MFDA to establish minimum standards for Approved person trading in ETFs as we believe strongly in higher investment education standards. Of particular interest to us is the proposed requirement for Approved Persons to receive ETF product-specific training through courses offered through independent providers or through the Member, and we agree that in either case the training must meet the specified minimum product training requirements set out in Appendix A to the Proposed Policy.
Overview of the Council’s Comments:
As a general comment, we wish to stress the importance of the CSA implementing, and the MFDA supporting, a regulatory best interest standard on all persons providing investment advice, including with respect to ETFs and mutual funds. Such a standard would help ensure that an investment or allocation of financial resources is in fact in a client’s best interests, and would help mitigate concerns relating to potential conflicts of interest, particularly as it relates to decoupling financial or planning advice from sales commissions. The end users of these services and the investment industry would benefit if all professionals offering investment advice were held to this high standard.