“Attach [amendments] Reflects regulatory principles, investor benefits and joint report,” the letter said.
It also referred to the 2019 joint report prepared by IIROC and Accenture on the evolution of advice in Canada, which discussed changing customer expectations. In addition to supporting their individual financial objectives, it said many customers are looking for an approach that considers the financial objectives of the “whole family or ‘household’.
“Similarly, the focus on individual accounts has also begun to shift to a greater focus on ‘home’ and in some cases, extended, multi-generational family planning,” the report said.
The report also highlights the notion that the regulatory system operates in a slow, responsive fashion, while not focusing enough on the right activities. The report highlighted the “increasingly complex continuum” of relationships managed by multiple firms, ranging from individual investment clients to multi-generational families with financial plans.
“The focus on holistic financial – planning advice and a single account-to-household account (which can include multiple financial goals and time frames) more than product-based advice does not translate easily to our current rules and guidance and how IIROC have traditionally interpreted them,” said the 2019 joint report.