With respect to addressing compensation arrangements in mutual funds, while a next step includes the development of proposals to address conflicts of interest created by compensation arrangements, there does not appear to be a set time limit for the proposed publication of those proposals, and the “expected outcomes” only refers to an action plan and recommendation. We believe that a specific deadline should be set and we would welcome action to move this initiative forward as quickly as possible. We urge the OSC to try to work with its counterparts in other jurisdictions to complete their analysis as soon as possible such that new rules, if any, can also be published for comment as soon as possible.
Overview of the Council’s Comments:
We continue to believe it would be helpful for market participants if there were clear, published criteria for measuring the success of a particular new rule or guidance. If the success of a new rule is measurable and monitored, consideration of any necessary amendments can take place in a timely manner. Roundtables are a practical, efficient method of collecting information from market participants when formulating new rules or amendments, and we would be pleased to continue to participate on a going forward basis.