Proposed NI 23-102 Use of Client Brokerage Commissions

March 20, 2008

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Proposed NI 23-102 Use of Client Brokerage Commissions

Letter Summary:

In almost all cases, we are in favour of those regulations and protocols which enhance the transparency, competitiveness and liquidity of Canada’s capital markets. As outlined in the CFA Institute’s Soft Dollar Standards we believe that an investment manager should provide full and fair disclosure to a client on the usage of their brokerage commissions; that this disclosure and presentation should be consistently presented amongst clients so as to understand the investment manager’s brokerage practices; and that this disclosure should be uniform and have sufficient record keeping so as to allow clients to understand the investment manager’s usage of brokerage commissions. A copy of the CFA Institute Soft Dollar Standards is enclosed with this letter.

Overview of the Council’s Comments:

We believe that the amount of time required for the transition to the rules outlined in the Proposed Instrument should be directly related to the quantity and quality of the disclosure required by the instrument. The greater the precision and quantity of data required to be disclosed, the greater the amount of time that will have to be taken to collect, analyze, synthesize and publish this data.