FPSC Comments on Consultation
Draft Regarding OSC-FSCO Merger
June 29, 2001
Mr. John R. O'Toole, M.P.P. Parliamentary Assistant
to the Minister of Finance 7 Queen's Park Crescent Frost Building South, 7th Floor Toronto, ON M7A 1Y7
Dear Mr. O'Toole:
Re: Establishing a Single Financial Services
Regulator - Consultation Draft.
As the standard setting body that awards the
Certified Financial Planner® (CFP®) designation
in Canada, Financial Planners Standards Council (FPSC) has
a significant interest in the proposed merger of the Ontario
Securities Commission (OSC) and the Financial Services Commission
of Ontario (FSCO).
The merger will obviously affect over 6,500 CFP
professionals who work in Ontario, a high percentage of whom are
licensed to sell mutual funds and/or insurance products. We
also recognize that the merger may be used as a template for
future consolidation on a national level, which will obviously
affect over 6,000 Canadian advisors currently licensed to
use the CFP designation in other provinces.
We are concerned by what appears to be an uneven
and disproportionate distribution of power within the structure
of the proposed Ontario Financial Services Commission as set
out in the consultation draft. The province's pension and
insurance sectors are significantly larger than the securities
industry not only in the number of people they employ, but
also in the extent of assets under administration. The governance
structure as proposed, however, creates a Board of Directors
in which OSC members could outnumber FSCO members by more
than three to one. It also seems insurance and pensions fall
under the supervision of one or two Superintendents, who would
be employees ranking below both the Vice-Chairs and the Chair.
We think it unreasonable that the securities
regulator should completely dominate the new Ontario Financial
Services Commission. In order to maintain balance and retain
appropriate regulatory expertise, FPSC believes that two persons
with an extensive background in the insurance and pension
sectors should be named Deputy Chairs for insurance and pensions
respectively. FPSC envisions these new Deputy Chairs as positions
senior to those of the Vice-Chairs.
We also believe that representatives from the
insurance and pension sectors should have an opportunity to
play a much more significant role in the amalgamation process,
and that a task force made up of industry representatives
should be established in order to examine these issues in
greater detail before proceeding with undue haste.
Thank you for the opportunity to comment on this
important legislation.
Yours sincerely,
Donald J. Johnston, President
CFP®, CERTIFIED FINANCIAL PLANNER® and are certification marks owned outside the U.S. by Financial Planning Standards Board Ltd. (FPSB). Financial Planners Standards Council is the marks licensing authority for the CFP marks in Canada, through agreement with FPSB.
are certification marks