A few quick thoughts re the CSA’s Status Report on mutual fund fees…

Status report?  The only part I can see dealing with the status (after a quick skim of the document) is the following:

”CSA staff continue to consider and discuss the information gathered through our consultative process with a view to determining next steps.”

Which raises the question, “are they only considering information gathered through the consultation process?”.  I hope not. 

References noted in the industry points (4 to 25 inclusive) outnumbered those in the consumer points (26 to 31 inclusive).  

The following is a worryingly naive admission.  

“…similarity of the feedback received from stakeholders demonstrates a connection between the two consultation initiatives and suggests a need for CSA staff to coordinate their policy considerations on these initiatives going forward.”

Importantly, do the points laid out represent the CSA’s points of reference for establishing their eventual views? Is this the summary they will be using to base their final decision?  If so do you feel confident that their interpretation and distillation of the arguments is appropriate in the context of the importance of the outcome?

The industry has the funds to commit to responding this document, but the consumer does not.  Note the recent outtake from the IAP annual report:

In last year’s Annual Report, the Panel expressed concern and some frustration with the limited resources to support its work, particularly with regard to research. The Panel continues to struggle with its limited budget and staff resources. While staff support from the Office of the Investor dramatically improved throughout the year, we continue to find access to drafting and writing support a challenge. ……we remain concerned about our ability to effectively and efficiently fulfill our requirements under our mandate

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