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Saskatchewan’s consultation period on the regulation of financial planners and financial advisors ends Monday. In its submission, the Investment Industry Association of Canada (IIAC) highlighted potential gaps in the regulation of financial planners and said title regulation shouldn’t extend to “financial advisor.”

Last month, the Financial and Consumer Affairs Authority (FCAA) of Saskatchewan requested comment on title regulation, asking specifically for views on whether the province should take the same approach as Ontario, which passed the Financial Professionals Title Protection Act last May. The Financial Services Regulatory Authority of Ontario (FSRA) continues to work with stakeholders to develop related policies and regulations.

Read: Province’s plan to regulate planner and advisor titles gets thumbs-up from industry

In its submission letter to Saskatchewan’s FCAA, the IIAC said regulations must be “examined closely” to ensure they provide clarity for the industry and investors.

For example, the FCAA must articulate what activity it intends to capture, and who exactly is a financial planner, IIAC said.

As outlined in its previous submissions to the Ontario government, IIAC recommended in its submission to the FCAA that regulation of financial planners extend to those who use the title, as well as to those who provide comprehensive financial plans.

It defined a comprehensive financial plan as a “complex written plan” prepared as part of an integrated financial planning process encompassing many areas, including financial management, insurance, risk management, investment planning, retirement planning, tax planning, estate planning and legal aspects.

IIAC distinguished such plans from the planning provided by financial advisors who aren’t financial planners, such as investment or retirement planning.

It also said that focusing on titles alone is insufficient to protect consumers. Also required is determining if someone is providing activity that falls under a definition of financial planning.

IIROC-regulated firms expect their financial planners to have acceptable financial planning credentials, IIAC added, saying it will continue to provide comments on recognized credentials as the proposed framework continues to be developed.

Regulating financial advisors

IIAC also urged the FCAA to reconsider regulation of “financial advisor” because of the title’s broadness.

“Previously proposed definitions by the Ontario government would theoretically cover any individual within the entire realm of the financial services industry,” the submission said.

Further, financial advice is already “highly regulated,” it said. As such, developing regulations for financial advisors in Saskatchewan that might contradict with established regulations would be “duplicative and inefficient.” It would also be confusing and potentially result in alternative standards in Saskatchewan and Ontario relative to the rest of the country.

Thus, IIAC recommended that the FCAA focus on financial planners only, as well as those who provide comprehensive financial plans.

(Despite its misgivings about regulating “financial advisor,” IIAC said anyone using that title should be a professional meeting regulator’s requirements.)

It also urged country-wide harmonization of titles for “all those engaged in the financial services industry” and for any regulatory framework for financial planners.

Read the IIAC’s full submission to the FCAA of Saskatchewan.