Proposed Framework 81-406 Point of Sale Disclosure for Mutual Funds and Segregated Funds

October 15, 2007

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Proposed Framework 81-406 Point of Sale Disclosure for Mutual Funds and Segregated Funds

Letter Summary:

The CAC is concerned that too many investors focus on short term results, while investing should have a long term time horizon. Therefore if Fund Facts are updated too frequently there may be undue consideration of the short term results. Therefore we are of the view that a quarterly update is sufficient for regulatory purposes. However, if there is a material change in the management, fees, structure or governance of the fund then the Fund Facts should be updated immediately.

Overview of the Council’s Comments:

The CAC believes in timely disclosure and information. Mutual Funds should be purchased as long-term investments and selection is frequently made based on the manager’s past performance. At a minimum, quarterly information should be available on the Fund Company’s website.