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Letter Summary:
We hope the CSA will take our comments into consideration and review the proposal for NI 23-102. These proposed new rules will have a significant impact and we do not believe that, in their current form, these CSA rules and policies are achieving the goals originally set forth. Moreover, these rules place an unfair financial burden upon Canadian advisors in order to attain their compliance and may reduce their global competitiveness. In short, we feel more consultation is required prior to adopting new rules on soft dollars.
Overview of the Council’s Comments:
The CSA have recognized that prohibiting soft dollar commissions could put Canada at a competitive disadvantage and threaten the viability of Canadian independent research. The goals of this policy initiative were to provide investors with more information about their adviser’s use of soft dollar commissions, to harmonize and clarify the rules for goods and services that can be purchased with client commissions and to increase confidence that commissions are ultimately benefiting those that pay them. The CSA are also committed to delivering cost-effective regulation.