Mutual Fund Dealers Association of Canada - Association canadienne des courtiers de fonds mutuels
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Mutual Fund Dealers Association of Canada
Association canadienne des courtiers de fonds mutuels
Annual Report
Raising the standard of
regulation in Canada
2010
Table of Contents Joint Message from the Chair and President MFDA Membership Information Corporate Governance Regional Councils and Hearing Panels MFDA Regulatory Operations Compliance Enforcement Policy Membership Services Management Discussion and Analysis Management’s Responsibility for Financial Reporting Financial Statements
Joint Message from the Chair
and President
The MFDA Board of Directors experienced significant change in fiscal 2009-2010,
with the introduction of six new Public Directors and one new Industry Director
between November 2009 and March 2010. The new Directors bring a variety and
wealth of experience to the Board.
The new Board and senior staff recognize the contributions of Directors who stepped
down last year and we thank George Aguiar, Martin Friedland, William Grace,
Helen Meyer, Janet Pau and Robert Wright for their dedication and leadership.
Their contributions are reflected in the Canadian Securities Administrators’ Oversight
Review Report of the MFDA, released in July 2010, which concludes that the “MFDA’s
Compliance and Policy Departments continue to guide its maturing membership
towards a culture of compliance” and notes that “Generally, the MFDA’s processes
are efficient, effective, consistent, and fair; and it has adequate staffing, resources and
training processes to perform its regulatory functions effectively and efficiently.”
While the report’s overall findings are positive and tell us that we are doing many things
right, we know that there is room for improvement and we will continue to strive for the
highest standards and best practices at every level of the organization.
As President and CEO, I welcome Rod McLeod as a new Public Director and Chair of
the Board. His legal and regulatory experience, both as a “regulator” and, laterally, as a
lawyer in private practice representing private sector business organizations impacted
by regulators, will be very helpful.
Together, we both welcome the other new Board members: Sonny Goldstein, Sandy
Grant, Lea Hansen, Dawn Russell, Doug Thomson and Janet Woodruff. The MFDA is
committed to on-going dialogue with its stakeholders and will continue to meet with
regulators, Members, investor representatives and industry associations on a regular
basis. Experience tells us that obtaining real-time information about industry practices,
concerns and problems facing Members and investors is crucial to the MFDA’s ability
to meet its regulatory goals.
We conclude by thanking the MFDA’s management and staff. Their skill, integrity
and dedication ensure that the MFDA continues to raise the standard of regulation
in Canada for the protection of investors through commitment to collaboration,
staff excellence and regulatory best practices.
Rod M. McLeod, Q.C. Larry M. Waite
Chair, MFDA Board of Directors President & Chief Executive Officer
Mutual fund dealers association of canada 1
MFDA Membership Information
The MFDA is Canada’s national self-regulatory organization responsible for regulating
the activities and operations of 139 mutual fund dealer firms (“Members”) and their
approximately 73,000 salesperson (“Approved Persons”). These Members accounted
for approximately $271 Billion of the approximately $592 Billion of client assets under
administration in the Canadian mutual fund industry as at June 30, 2010.
There are four principal categories of MFDA Membership.
• Level 1 Member - an introducing dealer that is not a Level 2, 3 or 4 Member.
• Level 2 Member - a dealer that does not hold client cash, securities or other property
(i.e. the Member does not operate a trust account and conducts business in client
name only).
• Level 3 Member - a dealer that does not hold client securities or other property except
client cash in a trust account.
• Level 4 Member - includes all other Members (including a Member that acts as a
carrying dealer).
The MFDA presently operates in Québec pursuant to a Cooperative Agreement with the
Autorité des marchés financiers and the Chambre de la sécurité financière. Accordingly,
the information set out in the tables below does not reflect Member activities based in
the province of Québec.
Number of MFDA Members by Category Level (as at June 30)
2006 2007 2008 2009 2010
Level 1 Nil Nil Nil Nil Nil
Level 2 61 54 53 46 46
Level 3 69 63 64 59 55
Level 4 45 45 42 40 38
2 Mutual fund dealers association of canada
MFDA Membership Profile (as at June 30)
2006 2007 2008 2009 2010
Number of Members 175 162 159 145 139
Number of Approved Persons 69,691 71,086 73,455 74,768 73,291
Assets Under Administration of all Members $ 276 B $ 310 B $ 304 B $ 252 B $ 271 B
Total Industry Assets Under Administration $ 589 B $ 707 B $ 700 B $ 547 B $ 592 B
Location of Member Head Offices (as at June 30)
2006 2007 2008 2009 2010
Ontario 119 111 106 96 93
British Columbia 15 15 15 14 12
Québec 14 9 10 10 12
Alberta 8 8 9 8 7
Manitoba 7 7 7 7 6
Saskatchewan 6 6 6 4 4
Nova Scotia 3 3 3 3 3
New Brunswick 3 3 3 3 2
Total 175 162 159 145 139
Member Assets Under Administration per Head Office (as at June 30)
2006 2007 2008 2009 2010
Ontario $ 201.1 B $ 220.3 B $ 218.7 B $ 175.8 B $ 190.2 B
Manitoba 46.7 B 55.7 B 52.4 B 45.7 B 48.9 B
British Columbia 13.5 B 16.4 B 16.5 B 13.6 B 14.8 B
Québec* 6.4 B 7.8 B 7.2 B 9.9 B 10.5 B
Saskatchewan 4.4 B 5.0 B 4.6 B 3.4 B 3.5 B
Alberta 3.1 B 3.9 B 3.8 B 3.1 B 2.5 B
New Brunswick 0.5 B 0.6 B 0.5 B 0.4 B 0.2 B
Nova Scotia 0.2 B 0.2 B 0.2 B 0.1 B 0.1 B
Total (rounded) $ 276 B $ 310 B $ 304 B $ 252 B $ 271 B
* The figures reflect assets outside the province of Québec for dealers with a Head Office in Québec.
Mutual fund dealers association of canada 3
Number of Members by Assets Under Administration 2006 2007 2008 2009 2010 $100 Million and Under 79 65 69 70 65 $101 Million to $500 Million 52 51 45 36 35 $501 Million to $1 Billion 11 11 11 12 11 Over $1 Billion 33 35 34 27 28 Total 175 162 159 145 139 Number of Members by Firm Size 2006 2007 2008 2009 2010 10 Approved Persons or Fewer 74 67 64 59 57 11 to 100 Approved Persons 57 52 50 46 42 101 to 500 Approved Persons 24 21 23 18 17 501 to 1,000 Approved Persons 6 7 7 7 7 Over 1,000 Approved Persons 14 15 15 15 16 Total 175 162 159 145 139 Staff of the MFDA’s Toronto Office. 4 Mutual fund dealers association of canada
MFDA Vision Raising the standard of regulation in Canada for the protection of investors through commitment to collaboration, staff excellence and regulatory best practices.
Corporate Governance
This section contains information about the composition of the MFDA Board of Directors,
terms of office, compensation and the composition of each Committee, as well as
information regarding Directors’ attendance at Board and Committee meetings. Further
biographical information on the current Directors can be found at www.mfda.ca.
Board of Directors
Below is the composition of the Board of Directors as at July 1, 2010.
Public Directors
Roderick M. McLeod, Q.C. (Chair) Lea B. Hansen, CFA Doug Thomson, FCA
Lawyer, Part-time Counsel Corporate Director Corporate Director
Miller Thomson LLP (Toronto, Ontario) (Edmonton, Alberta)
(Markham, Ontario) Joined Board: January 2010 Joined Board: January 2010
Joined Board: March 2010 Term expires: AGM 2012 Term expires: AGM 2011
Term expires: AGM 2012
Dawn A. Russell, Q.C. Janet P. Woodruff, CA
Sandy (D.W.) Grant, CA Associate Professor Vice-President & Special Advisor
Corporate Director Schulich School of Law BC Hydro
(Orillia, Ontario) Dalhousie University (Vancouver, British Columbia)
Joined Board: March 2010 (Halifax, Nova Scotia) Joined Board: January 2010
Term expires: AGM 2011 Joined Board: November 2009 Term expires: AGM 2011
Term expires: AGM 2012
6 Mutual fund dealers association of canada
Left to Right: Bob Sellars, Ed Legzdins, Larry Waite, Peter Glaab, Sandy Grant, Steve Geist, Rod McLeod,
Janet Woodruff, Kevin Regan, Doug Thomson, Dawn Russell, Sonny Goldstein, Lea Hansen
Industry Directors
Ed Legzdins, CA (Vice-Chair) Peter W. Glaab, CMA Kevin E. Regan, CA, CFP
Senior Vice-President, Senior Vice-President President & Chairman of the Board
Retail Investments & CI Investments Inc. Investors Group Financial Services Inc.
Managing Director, International (Toronto, Ontario) (Winnipeg, Manitoba)
BMO Financial Group Joined Board: December 2004 Joined Board: December 2005
(Toronto, Ontario) Term expires: AGM 2010 Term expires: AGM 2011
Joined Board: December 2005
Term expires: AGM 2011 Sonny Goldstein, CFP Robert M. Sellars, CA, CFA
President Executive Vice-President & Chief
Stephen Geist, CA, CFP Goldstein Financial Investments Inc. Financial Officer
President (Toronto, Ontario) Dundee Private Investors Inc.
CIBC Asset Management Inc./CIBC Joined Board: March 2010 (Toronto, Ontario)
Securities Inc. Term expires: AGM 2010 Joined Board: December 2006
(Toronto, Ontario) Term expires: AGM 2010
Joined Board: December 2008
Term expires: AGM 2010
Mutual fund dealers association of canada 7Board Committees
The MFDA Board has four standing committees – Audit & Finance, Executive,
Governance and Regulatory Issues. The President and CEO of the MFDA is an
ex officio member of all four committees. The composition and mandate of each
Committee is outlined below.
Audit & Finance Committee
The Audit & Finance Committee oversees internal and external audits of the MFDA
and advises the Board on financial issues including the Management Discussion
and Analysis and the financial statements. The Committee oversees MFDA risk
management internal control functions and reviews the MFDA budget.
The Committee must be chaired by a Public Director.
Committee Members
Doug Thomson (Chair) Public Director
Peter Glaab Industry Director
Sandy Grant Public Director
The Audit & Finance Committee met four times during fiscal 2009/2010.
Executive Committee
The Executive Committee meets, when required, to review any matter that the Chair
or the President and CEO does not consider to be within the mandate of any other
Committee and to carry out such other functions as are assigned or delegated to it by
the Board. The Committee is currently chaired by an Industry Director.
Committee Members
Ed Legzdins (Chair) Industry Director
Rod McLeod Public Director
Robert Sellars Industry Director
Janet Woodruff Public Director
The Executive Committee met once during fiscal 2009/2010.
8 Mutual fund dealers association of canadaGovernance Committee
The Governance Committee’s responsibilities include the coordination and oversight of
the Director nomination process, recommendations for Committee membership and
Board self-assessments. The Committee must be chaired by a Public Director.
Committee Members
Rod McLeod (Chair) Public Director
Ed Legzdins Industry Director
Dawn Russell Public Director
Robert Sellars Industry Director
The Governance Committee met 14 times during fiscal 2009/2010.
Regulatory Issues Committee
The Regulatory Issues Committee’s responsibilities include the review of proposed
Policy, Rule or By-law amendments to be presented to the Board and review of
applications from Members for exemptive relief from MFDA regulatory requirements.
The Committee must be chaired by a Public Director.
Committee Members
Dawn Russell (Chair) Public Director
Stephen Geist Industry Director
Sonny Goldstein Industry Director
Lea Hansen Public Director
Kevin Regan Industry Director
Robert Sellars Industry Director
The Regulatory Issues Committee met four times during fiscal 2009/2010.
Ad Hoc Committees
In March 2010, the Board established the IPC Issues Committee to consider a number
of proposals made by the MFDA Investor Protection Corporation (“IPC”), including
(a) increasing the target size of the IPC fund from $30 million to $50 million over five
years; (b) aligning the asset base on which IPC assessments are calculated with assets
currently covered by the fund; and (c) aligning the risk of Member insolvency with
assessments.
In June 2010, the IPC Issues Committee made a number of recommendations (see
Bulletin #0437-M) on which Members were invited to comment by September 1, 2010.
The Committee held an information session for Members on July 15, 2010 and met with
members of the Investment Funds Institute of Canada and the Federation of Mutual
Fund Dealers on July 28, 2010. The Committee’s final recommendations are subject to
Board approval.
Mutual fund dealers association of canada 9Amendments to MFDA By-law No. 1
A Special Meeting of Members was held on October 2, 2009 at which Members
approved the amendments to MFDA By-law No. 1 set out in By-law No. 15 by the
requisite two-thirds of votes cast at the meeting. Following the meeting, a Member
filed a Notice of Request for Review of Decision with the British Columbia Securities
Commission (“BCSC”) concerning the amendments.
In January 2010, the BCSC advised the MFDA that the Canadian Securities
Administrators’ (“CSA”) approval of By-law No. 15 could not be expected until at least
the completion of the proceedings noted above and so the MFDA held its Annual
General Meeting of Members in March 2010 under the existing version of By-law
No. 1. In April 2010, the MFDA and the Member that initiated the BCSC proceeding
made a joint application to the BCSC Hearing Panel to discontinue the proceeding.
However, in June 2010 the Hearing Panel rejected the parties’ application and
determined that it was in the public interest to hold a hearing. At the time of printing
this Annual Report, the proceeding was still underway.
Director Compensation
As part of its mandate, the Governance Committee reviewed the MFDA’s Director
Compensation Policy to ensure that it is adequate and in line with similar organizations.
Public Director remuneration remains unchanged from 2009. Each Public Director on
the MFDA Board receives an annual retainer of $15,000. The Committee Chair retainer
for all committees, with the exception of the Audit & Finance Committee, is $2,500 per
annum. The Audit & Finance Committee Chair retainer is $4,000 per annum. Public
Directors receive a meeting attendance fee of up to $1,500 per Board or Committee
meeting. Out-of-town Public Directors who attend Board or Committee meetings in
person receive an additional $1,000 supplementary fee.
In circumstances where a Public Director serves as the Chair of the Board, the Board of
Directors has the discretion to set the amount of the Chair retainer, which is reviewed
annually during the tenure of the individual. The annual retainer for the Chair of the
Board is $50,000 compared to $70,000 in 2009.
Industry Directors are not compensated for their participation on the MFDA Board,
however, all Directors are reimbursed for related travel and out-of-pocket expenses.
Board Orientation
New Directors participated in a comprehensive orientation session following their
appointment to the MFDA Board. The orientation provided an overview of the MFDA’s
regulatory mandate, its operations, financial affairs, legal framework and governance
practices. The session also provided new Board members with an opportunity to meet
senior management and be briefed on their specific roles within the Corporation.
10 Mutual fund dealers association of canadaCode of Conduct
In 2009, the MFDA formalized a Code of Conduct for Directors as a practical guide for
Board members. The Code includes provisions designed to minimize the possibility
of bias and conflicts of interest which may arise from the use of information obtained
during the course of Directors’ duties.
Board and Committee Meeting Attendance
A total of 38 meetings were held during the fiscal year ended June 30, 2010, including
13 Board meetings, one Special Meeting of Members and one Annual General Meeting
of Members. Below is a breakdown of attendance.
Director Board of Audit & Finance Executive Governance Regulatory
Directors Issues
George Aguiar (departed March 4/10) 8 of 9 n/a 1 of 1 9 of 10 2 of 3
Martin Friedland (departed March 4/10) 9 of 9 n/a n/a 10 of 10 n/a
Stephen Geist 9 of 13 n/a n/a n/a 3 of 4
Peter Glaab 11 of 13 4 of 4 n/a n/a n/a
Sonny Goldstein ( joined March 4/10) 4 of 4 n/a n/a n/a 1 of 1
William Grace (departed Dec. 21/09) 5 of 6 2 of 2 1 of 1 n/a 2 of 2
Sandy Grant ( joined March 4/10) 4 of 4 1 of 1 n/a n/a n/a
Lea Hansen ( joined Jan.12/10) 6 of 6 n/a n/a n/a 2 of 2
Ed Legzdins 10 of 13 n/a 1 of 1 13 of 14 n/a
Rod McLeod (appointed March 4/10) 3 of 3 n/a n/a 4 of 4 n/a
Helen Meyer (departed Dec. 22/09) 6 of 6 n/a n/a n/a 2 of 2
Janet Pau (departed Dec. 21/09) 5 of 6 2 of 2 n/a n/a n/a
Kevin Regan 11 of 13 n/a n/a n/a 3 of 4
Dawn Russell ( joined Nov. 4/09) 7 of 8 n/a n/a 4 of 4 2 of 2
Robert Sellars 13 of 13 n/a n/a 4 of 4 4 of 4
Doug Thomson ( joined Jan.12/10) 6 of 6 2 of 2 n/a n/a n/a
Larry Waite 13 of 13 4 of 4 1 of 1 14 of 14 4 of 4
Janet Woodruff ( joined Jan.12/10) 6 of 6 1 of 1 n/a n/a n/a
Robert Wright (departed Feb. 1/10) 8 of 8 n/a 1 of 1 9 of 9 n/a
Mutual fund dealers association of canada 11Regional Councils and
Hearing Panels
The MFDA has four Regional Councils corresponding to the following
geographic Regions:
• Atlantic Region: N
ova Scotia, New Brunswick, Prince Edward Island and
Newfoundland and Labrador
• Central Region: Ontario and Québec
• Pacific Region: British Columbia and Yukon Territory
• Prairie Region: Alberta, Saskatchewan, Manitoba, Northwest Territories
and Nunavut
The principal activity of the Regional Councils is the conduct of hearings by three-
person Hearing Panels created from among members of each Regional Council.
The membership of each Regional Council includes elected industry representatives,
(partners, officers, directors, employees or agents of Members resident in the Region),
appointed public representatives and appointed industry representatives. The primary
role of representatives is to serve on MFDA disciplinary Hearing Panels, each of which
is chaired by a public representative who is generally a retired judge but may also be a
lawyer with extensive litigation and administrative law experience.
The two-year terms of office of elected industry representatives on the Regional Councils
expired in June 2010 and the MFDA conducted a formal nomination and election
process to re-constitute the Councils in Spring 2010. The Board of Directors approved
the new Chairs and Vice-Chairs of the Regional Councils at its June 2010 meeting.
Further details regarding the composition of the 2010-2012 Regional Councils are
outlined on the MFDA website.
Newly elected industry representatives are provided with a day-long orientation program
prior to serving on a Hearing Panel. The program is presented by an external expert in
administrative law and tribunal conduct and is focused on educating potential panelists
on how to conduct disciplinary proceedings as well as providing background on the
MFDA’s legal framework, compliance and enforcement functions.
12 Mutual fund dealers association of canadaMFDA Regulatory Operations
MFDA regulatory operations are organized among the following Departments:
Compliance, Enforcement, Policy and Membership Services.
COMPLIANCE
The Compliance Department is responsible for monitoring Members’ adherence
to MFDA requirements and is comprised of two groups: Sales Compliance and
Financial Compliance. The Compliance Department is also responsible for reviewing
and approving Member resignation and reorganization requests, reviewing new
membership applications and assisting in policy and enforcement initiatives
as required.
Sales Compliance
Third Compliance Examination Cycle
MFDA Members are subject to a compliance examination within a three-year cycle.
The MFDA’s third cycle of compliance examinations commenced in January 2009 and
staff performed 60 head office examinations and 156 branch examinations through to
June 30, 2010.
All Reports issued to date have been issued within the established benchmarks.
The following is a breakdown of compliance examinations by province as at
June 30, 2010.
Head Office Branch Total
Ontario 38 81 119
British Columbia 7 25 32
Alberta 2 18 20
Nova Scotia 1 10 11
Manitoba 4 6 10
New Brunswick 1 7 8
Saskatchewan 2 5 7
Québec 5 - 5
Newfoundland and Labrador - 3 3
Prince Edward Island - 1 1
Total 60 156 216
Mutual fund dealers association of canada 13Referrals to the Enforcement Department
Compliance made a total of 23 referrals to the Enforcement Department as at
June 30, 2010 originating from information received in the third cycle of
compliance examinations.
Financial Compliance
Level 4 Member Examinations
During calendar 2009, the Financial Compliance group satisfied its benchmark to
perform an annual on-site financial examination of all 37 active Level 4 Members.
Furthermore, all examination reports were issued within the established benchmarks.
Of the 37 examinations conducted during the period, 24 were in Ontario, 6 in Québec
3 in British Columbia and 2 each in Alberta and Manitoba.
As at June 30, 2010, sixth-round financial compliance examinations were being
performed for Level 4 dealers. A total of 24 sixth-round examinations had commenced,
of which eight reports had been issued as of June 30, 2010.
Financial Compliance Desk Reviews
The Financial Compliance group is responsible for reviewing the monthly financial
reports of all Members within 5 business days of the filing due date and the annual
audited financial reports within 3 months of the report date. During calendar 2009,
approximately 1,700 unaudited monthly and 140 audited annual financial reports
were reviewed by Financial Compliance staff within the established benchmarks. In a
number of instances, capital and/or reporting issues were identified through this review
process and Financial Compliance staff took steps to communicate with Member staff
on a timely basis so that corrective action could be taken.
Financial Compliance referred six matters to the Enforcement Department for the
12 months ended June 30, 2010, primarily relating to breaches of early warning
requirements and failure to notify the MFDA immediately of capital deficiencies.
Key Compliance Initiatives
Additional Member Guidance on Key Compliance Issues
In addition to the MFDA’s ongoing efforts to provide further guidance to Members
through its examinations process, Member Regulation Forums and industry and dealer
conferences, during calendar 2009 MFDA Compliance staff undertook various specific
initiatives to provide more guidance to Members on key compliance issues.
14 Mutual fund dealers association of canadaIn particular, Compliance staff issued Bulletin #0355-C – Common Sales Compliance
Deficiencies and Appropriate Corrective Action, which provides both general guidance
on how to address compliance deficiencies and develop an appropriate action
plan and specific guidance on how to address several of the most common
compliance deficiencies.
Compliance staff also commenced work on several written guides on specific compliance
topics to be made available on the MFDA’s public website and Members-only web site.
The first such guide issued in 2009 was the Policies and Procedures Manual Reference
Guide, which provides Members with a consolidated reference document that details all
of the necessary written Member policies and procedures annotated to the applicable
Rules, Policies and Notices.
In addition, Compliance staff worked extensively on developing additional guidance
and tools for Members on the topics of leverage supervision and suitability – one of the
largest areas of focus in the third cycle of examinations. While MR-0069 – Suitability
Guidelines provided significantly more guidance to Members and industry participants
on leverage supervision and suitability than had ever been provided previously in the
Canadian securities industry, compliance examination findings through 2009 indicated
that further guidance was still required. In response, Compliance staff created a Leverage
Supervision Guide and several supervisory tools including a Leverage Review Worksheet
and an Approved Person Leverage Analysis template to assist Members in meeting their
supervision and suitability obligations. The guide and associated supervisory tools were
issued in early 2010.
Member and Auditor Education
MFDA Financial Compliance staff has been performing, on an annual basis, on-site
examinations of Level 4 dealers’ financial operations for over five years. Members have
demonstrated an improvement in their understanding of the financial requirements
during this time. However, staff has identified a number of areas where Members have
incurred capital deficiencies as a result of not understanding or not fully complying
with the financial requirements. To address this weakness, the MFDA issued Bulletin
#0427-C in early 2010 highlighting these significant deficiencies with the expectation
that Members will review the issues against their current practices and rectify them
if applicable.
In addition to on-site examinations of Member operations, MFDA staff has been
reviewing the auditor working papers prepared in support of the auditors’ work relating
to their annual audit engagement of Members. Under MFDA Rules, auditors are required
to perform their audit of the Form 1 in accordance with Canadian auditing standards and
also perform specific audit procedures outlined in MFDA Rules. As a result of reviewing
auditor working papers, it was determined that not all auditors have been incorporating
Mutual fund dealers association of canada 15the specified MFDA audit requirements into their engagements. Consequently, the
MFDA issued Bulletin #0428-C in early 2010 highlighting these deficiencies in the
auditor year-end engagements of MFDA Members with the expectation that auditors
will review the issues identified and modify their engagements to incorporate
MFDA-specific requirements.
Looking Forward
International Financial Reporting Standards
In addition to amending Form 1, MFDA staff is also planning to develop an internal
training plan to ensure that all applicable staff is familiar with the new International
Financial Reporting Standards (“IFRS”) and, more specifically, proficient with the
requirements under the revised Form 1. Educational sessions for Member staff
regarding the changes to Form 1 are planned for the second half of 2010.
Electronic Filing System
The MFDA is in the process of developing a new electronic financial filing application
that will replace the existing system upon Members transitioning to the IFRS Form 1
basis of reporting.
Staff of the MFDA’s Calgary Office.
16 Mutual fund dealers association of canadaEnforcement
The Enforcement Department is responsible for addressing non-compliance with
regulatory requirements by Members and Approved Persons. The Department is
comprised of four groups: Case Assessment, Investigations, Litigation and Policy.
2009 Annual Trends
The number of complaints and other intake matters received by Case Assessment in
2009 increased by 35% from 2008. The increase was attributable to the period between
January to June 2009. In the latter part of 2009, the intake numbers decreased to the
same monthly levels as early 2008, and they have continued to remain at those lower
levels in 2010. Staff believes that the temporary increase in intake numbers relates to
the significant decline in the markets during that period.
Enforcement Priorities
The Enforcement Department reviews supervision by the Member and its supervisory
personnel in all cases it opens. This is an important part of our enforcement and
compliance strategy that focuses on addressing Members’ efforts in proactively avoiding
non-compliant situations by implementing effective supervisory regimes.
The Enforcement Department also reviews the Member’s complaint handling in all
cases involving a client complaint. Although the MFDA, as a regulator, does not provide
compensation, it robustly enforces the Member’s obligation to respond to complaints in
a fair and timely manner.
The following case types will continue to be a priority for the Enforcement Department,
given the high level of potential client harm:
• Suitability of investment and leveraging recommendations;
• Member supervision, including Approved Person compliance with Member
supervisory requirements;
• Complaint handling;
• Securities and other business outside the Member; and
• Abusive sales practices, including theft, fraud, personal financial dealings,
misrepresentations and unauthorized and discretionary trading.
Mutual fund dealers association of canada 17Disciplinary Action
Staff commenced 26 disciplinary cases during the past fiscal year, a decrease of 5
cases from the previous fiscal year. This was because several earlier cases had been
adjourned pending the results of a court decision involving an Investment Industry
Regulatory Organization of Canada (“IIROC”) matter that related to the jurisdiction
of a Self-Regulatory Organization (“SRO”) to proceed against former Approved Persons.
The court case was decided in favour of the SROs in the Fall of 2009 and much
of staff’s work during the fiscal year involved bringing the adjourned cases back on
track for a hearing.
In addition, staff identified 276 cases involving violations of a minor nature that did
not warrant formal disciplinary proceedings. Of the 276 minor violation cases, 106
were closed by Warning Letter, 169 by Cautionary Letter and one was closed with an
Agreement and Undertaking.
Looking Forward
Enforcement’s main priority will continue to be the suitability of investment and
leveraging recommendations regarding mutual funds, exempt securities and any
other product sold by Members.
Enforcement generally identifies suitability cases as ones involving Approved Persons
who make specific investment or leveraging recommendations, as well as cases
involving a failure to develop, implement and maintain supervisory procedures by
Members and supervisors.
Members have a supervisory duty to set clear procedures that meet regulatory
requirements, and to actively supervise investment and leveraging recommendations
made to clients by their Approved Persons. The majority of the supervision cases to
date have been against Members and have come from referrals from MFDA Sales
Compliance. There have also been some cases against individual Approved Persons
regarding suitability, primarily with regard to exempt products.
In the coming year, a number of current files are likely to result in additional
proceedings against Members regarding supervision, and there is the potential
for proceedings against individual Approved Persons for unsuitable investment
and leveraging recommendations regarding mutual funds.
18 Mutual fund dealers association of canadaPolicy
The principal role of the Policy Department is to monitor the effectiveness of MFDA
By-laws, Rules and Policies; recommend changes, where appropriate; draft new or
amended By-laws, Rules and Policies; and draft Notices and Bulletins for Members to
assist them with the interpretation and application of MFDA requirements. In addition,
the department provides consulting, legal, research and drafting support to the other
departments of the MFDA.
Consultations with Industry
In the Fall of 2009 and Spring of 2010, MFDA staff held eight Member Regulation
Forum meetings in Vancouver, Calgary, Winnipeg, Toronto and Montreal. MFDA
staff updated Members on various policy initiatives, including proposed Rule and
Policy amendments, guidance on how to address compliance deficiencies and recent
enforcement cases.
By-law Amendments
MFDA By-law No. 1 – Section 35 (No Actions Against the Corporation)
On February 19, 2010, the Recognizing Regulators approved proposed amendments to
section 35 of MFDA By-law No. 1 regarding the MFDA Investor Protection Corporation
(“IPC”). The proposed amendments are intended to: (i) ensure that IPC and its
directors, officers and personnel are adequately protected in the discharge of their
investor protection mandate from legal actions by Members, Approved Persons or other
persons under the jurisdiction of the MFDA; and (ii) provide for, within the MFDA
By-laws, the terms of the relationship between the MFDA and IPC and existing MFDA
and Member obligations to the IPC. The proposed amendments will be brought forward
for Member approval at the December 2010 Annual General and Special Meeting of
Members (“2010 AGM”).
Rule Amendments
MFDA Rules 2.2 (Client Accounts), 2.8 (Client Communications) and 5.3
(Client Reporting) and Policy No. 2 Minimum Standards for Account Supervision
On June 29, 2010, the Recognizing Regulators approved proposed amendments to Rules
2.2, 2.8, 5.3 and Policy No. 2, which were drafted to address the issues of clarity of the
Member/client relationship and performance reporting under the Client Relationship
Model (“CRM”) project, as well as various other regulatory issues identified by MFDA
Compliance and Enforcement staff. The MFDA CRM proposals will be brought forward
for Member approval at the 2010 AGM.
Mutual fund dealers association of canada 19Consequential Amendments Resulting from National Instrument 31-103
Registration Requirements and Exemptions
Consequential amendments to MFDA Rules resulting from National Instrument
31-103 (“NI 31-103”) were published for a 90-day comment period which expired on
March 23, 2010. The proposed amendments include changes to Rule 1.2 (Individual
Qualifications), Rule 2.4.2 (Referral Arrangements), Rule 2.5 (Minimum Standards
of Supervision), Rule 5.3 (Client Reporting) and Rule 5.6 (Record Retention).
On June 25, 2010, the CSA published proposed amendments to NI 31-103 for a
90-day public comment period, which include revisions to requirements with respect
to account statements and referral arrangements. As a result, the consequential
amendments to Rules 5.3 and 2.4.2 have been put on hold until the revisions to the
requirements under NI 31-103 are finalized. The other consequential amendments to
MFDA Rules were approved by the Recognizing Regulators in October 2010.
MFDA Rule 2.4.1 (Payment of Commission to Non-registered Entities)
Amendments to Rule 2.4.1 codify existing practice with respect to the payment of
commissions to unregistered corporations and are intended to allow Members and
their Approved Persons an appropriate degree of flexibility in how they structure
their business affairs, provided that certain conditions are satisfied. The revised Rule
came into effect on March 29, 2010 and is subject to ratification by Members at the
2010 AGM.
Proposed New MFDA Rule 2.4.4 (Transaction Fees or Charges) and Proposed
Amendments to MFDA Rule 5.1 (Requirement for Records)
Proposed new Rule 2.4.4 and proposed amendments to Rule 5.1 were published for a
90-day public comment period which expired on September 23, 2010. Proposed new
Rule 2.4.4 will require that, prior to the acceptance of an order, the Member inform the
client of any sales charge, service charge or any other fees or charges to be deducted in
respect of the transaction so that the client is able to make an informed decision with
respect to the order. Conforming changes are also proposed to Rule 5.1(b) by adding a
new subsection (iv), which will require Members to maintain records evidencing that
the client was informed of all fees and charges in accordance with Rule 2.4.4.
20 Mutual fund dealers association of canadaProposed Amendments to MFDA Rule 3.1.1 (Capital – Minimum Requirements)
Proposed amendments to Rule 3.1.1, which prescribes the minimum capital to
be maintained by Level 1, 2, 3 and 4 Members, are intended to harmonize MFDA
minimum capital requirements for Members that are licensed in multiple registration
categories with the minimum capital requirements under NI 31-103. The proposed
amendments were published for comment on August 13, 2010.
Proposed Amendments to MFDA Rule 3.3.2 (Segregation of Client Property – Cash)
Rule 3.3.2 requires Members to hold client cash in trust and segregate client cash
for investment in mutual funds separately from client cash for other investments
and prohibits Members from earning interest on client funds held in trust. The
requirements in Rule 3.3.2 respecting commingling and the allocation and payment
of interest on client cash held in trust are based on the provisions of Part 11
(Commingling of Cash) of National Instrument 81-102 Mutual Funds (“NI 81-102”).
Proposed amendments to Rule 3.3.2 and NI 81-102 were concurrently published
for a 90-day public comment period which expired on September 24, 2010.
The proposed amendments to Rule 3.3.2 are intended to remove commingling and
related restrictions from the Rule, while maintaining the requirement to keep client
cash segregated from Member property. The amendments will also permit Members
discretion as to whether they will pay interest on client cash held in trust, subject to
conditions, including a disclosure requirement on account opening, as to whether or
not such interest will be paid and, if so, at what rate.
Staff of the MFDA’s Vancouver Office.
Mutual fund dealers association of canada 21Form Amendments
Proposed Amendments to MFDA Form 1 – Financial Questionnaire and Report
Proposed amendments to MFDA Form 1 were published for comment on
August 13, 2010. The proposed amendments are intended to align MFDA
financial reporting requirements with IFRS.
Policy Amendments
MFDA Policy No. 3 Complaint Handling, Supervisory Investigations
and Internal Discipline
Amendments to Policy No. 3 were developed to address procedural issues identified by
clients who have filed complaints against Members and their Approved Persons and
provide further guidance with respect to the fair and prompt handling of complaints
by Members and supervisory investigations to be conducted by Members following
the receipt of a complaint. The amendments to Policy No. 3 became effective on
February 1, 2010.
MFDA Policy No. 6 Information Reporting Requirements
Consequential amendments to section 14 (Changes in Organizational Structure) of
Policy No. 6 have been proposed to conform to NI 31-103 and NI 33-109 Registration
Information by including references to the Ultimate Designated Person and Chief
Compliance Officer in the reporting requirements under this section. The proposed
amendments to Policy No. 6 were approved by the Recognizing Regulators in
October 2010.
Member Regulation Notices
Leverage Risk Disclosure – MR#0074 (Issue Date: May 19, 2010)
This Notice replaces Member Regulation Notice MR-0006 Borrowing Money to Buy
Securities (Leveraging), issued on March 16, 2001. The Notice attaches revised leverage
risk disclosure documents to be provided to clients and provides guidance with respect
to leverage risk disclosure requirements.
22 Mutual fund dealers association of canadaComplaint Handling – MFDA Policy No. 3 – MR#0073 (Issue date: April 6, 2010)
This Notice was issued to provide summary information and guidance on Parts
I and II of revised Policy No. 3 Complaint Handling, Supervisory Investigations and
Internal Discipline. The Notice also reminds MFDA Members that they are required
to implement policies and procedures for handling client complaints that address the
minimum complaint handling requirements set out in MFDA Policy No. 3 and attaches
the revised Client Complaint Information Form that must be provided to new clients
and to clients who submit a written complaint to the Member.
Looking Forward
National Instrument 31-103 Registration Requirements and Exemptions
In 2009 and 2010, MFDA staff continued to participate on CSA Registrant Regulation
Committees with CSA and IIROC staff to consider amendments to NI 31-103, which
came into force on September 28, 2009. The MFDA has proposed consequential Rule
amendments to ensure consistency with requirements under NI 31-103. MFDA staff
will also be reviewing and revising Member Regulation Notices affected by these
amendments.
Powers of Attorney and Similar Authorizations
MFDA staff is currently drafting a Member Regulation Notice that is intended to clarify
the obligations of Members and Approved Persons with respect to powers of attorney
and similar authorizations such as executorships and trusteeships. The Notice will
update and replace Member Regulation Notice MR#0031 Powers of Attorney –
Rule 2.3.1 – Exception for Family Members of
Approved Persons, issued on October 29,
2004, and provide clarification with respect
to the requirements of the Rule.
Approved Person Transfers
MFDA staff is preparing a Member
Regulation Notice intended to identify
concerns with respect to some of
the account transfer practices that
MFDA staff has observed and to remind
Members and Approved Persons of
applicable regulatory requirements.
Staff of the MFDA’s Toronto Office.
Mutual fund dealers association of canada 23Amendments to Rule 2.2 (Client Accounts) and Policy No. 2 Minimum Standards for
Account Supervision
MFDA staff is currently drafting amendments to Rule 2.2 and Policy No. 2 to clarify
that the obligation for Members and Approved Persons to ensure that each order
accepted or recommendation made for any account of a client is suitable includes
recommendations to borrow to invest (“leverage”). Amendments to Policy No. 2 will
also clarify that the suitability of leverage must be assessed having regard to the client’s
investment knowledge, risk tolerance, age, time horizon, income and net worth and set
out minimum criteria that would require further supervisory review and investigation.
Membership Services
The Communications and Membership Services group is active in maintaining
Member files and responding to inquiries from Members, the public and the media.
It is also responsible for maintaining and updating the MFDA website and facilitating
Member events.
During the period July 1, 2009 to June 30, 2010, the Department responded to
approximately 900 inquiries by telephone and e-mail. The majority of inquiries come
from MFDA Members and Approved Persons respecting such topics as registration of
Approved Persons, the Electronic Filing System and questions about the latest Notices
and Bulletins.
Staff of the MFDA’s Toronto Office.
24 Mutual fund dealers association of canadaManagement Discussion and Analysis
The financial statements present the financial results of the MFDA for the fiscal year
ended June 30, 2010 with 2009 comparatives and accompanying notes.
Revenues
For FY 2010, the MFDA had revenues from operations of $25,366,717 (compared to
$25,807,652 for FY 2009). The principal source of revenue for the MFDA is Membership
fees, which are assessed against Members and are calculated to provide sufficient
funding to meet the MFDA’s yearly budgeted expenses.
Membership fees are calculated based upon a formula that takes into account the
amount of assets under administration (“AUA”) that each Member has under its control.
Each year, on or before April 15th, MFDA Members are required to report their AUA
figures as at March 31st. AUA figures represent AUA from operations in all provinces
other than Québec and specifically exclude cash, GIC’s, limited partnerships, and
segregated funds. A Member’s reported AUA at March 31st for the current year is then
added to the previous year’s reported AUA and an average of the two years is calculated
for billing purposes.
The MFDA uses a five-tiered AUA rate schedule as the basis for its billing. Members
are billed a set fee amount per million dollars of AUA based upon this schedule with
the fee rates set to provide sufficient funding for the next fiscal year. The MFDA fee
payable by a Member is calculated by matching its average AUA figure to this tiered fee
schedule. For some Members, a minimum fee applies. Each Member’s fees for the year
are divided into four installments payable on a quarterly basis.
Membership fees for FY 2010 amounted to $24,724,881. Other sources of revenue for
the MFDA include the following:
• Hearing cost recoveries of $438,511 are costs related to hearings held by the MFDA.
In December 2008 the MFDA Board of Directors approved the recovery of these costs
through the use of fine monies collected in the MFDA’s Discretionary Fund.
• Investment income of $37,749 is derived from the investment of MFDA operating
cash balances in the CIBC Imperial Money Market Pooled Fund and Canadian federal
treasury bills. Investment returns for FY 2010 were negatively impacted by the low
short-term interest rate environment experienced throughout the year.
• Enforcement recoveries of $100,476 are costs awarded by the MFDA Regional
Council Hearing Panels at the conclusion of MFDA disciplinary hearings or
settlements and which have been collected by the MFDA.
Mutual fund dealers association of canada 25• Administration recoveries of $60,000 are costs recovered from the MFDA IPC
for administrative services provided by MFDA staff.
• Late filing fees of $5,100 are fees levied against Members that have missed
information filing deadlines.
Expenses
Given the adverse economic environment facing MFDA Members for FY 2010, the
MFDA implemented a cost cutting strategy when it formulated its budget for the 2010
fiscal year. Primary among the cost cutting initiatives was a suspension of salary merit
increases for all staff, a reduction in Board member and Senior Executive remuneration,
restrictions on travel and training expenditures, and deferral of various technology
related projects. As a result of this cost cutting strategy, operating expenses for the
MFDA declined nearly $1 million or 3.6% year over year ($26,316,528 for FY 2010
compared to $27,312,601 for FY 2009).
Operating costs would have been substantially lower had it not been for the MFDA
having to defend itself before a BCSC hearing panel for which significant legal costs
were incurred. This hearing was the result of a complaint filed by a Member with
respect to the MFDA’s governance processes. Although the matter remains outstanding,
it is in the process of being resolved and going forward, substantially less legal
expense is anticipated to be incurred. Legal costs related to the BCSC hearing were
approximately $679,000 to the end of June 2010.
Staff related expenses remain the largest expense for the MFDA, representing 73%
of total expenses. The MFDA experienced a year over year decrease in salaries and
benefits expense for FY 2010 of $1,134,771 or 5.6%. This decrease arose mainly from
the suspension of salary merit increases for all staff that was effective throughout fiscal
2010 coupled with lower post-retirement benefits costs. The MFDA also experienced
modest staff turnover resulting in some vacant positions throughout the year which also
lowered salary expense. The MFDA completed fiscal 2010 with 162 employees which
was six positions short of the budgeted staff count of 168 positions. For fiscal 2011, the
budgeted staff count will be increased by two positions to 170 employees.
Overhead expenses such as rent and utilities, general office expenses, insurance,
telecom, bank charges, computer software and maintenance expenses collectively saw
a 1.6% year over year reduction from fiscal year 2009. Cost cutting measures and the
deferral of some IT related initiatives contributed to the savings. Restrictions placed
upon travel and training throughout the year achieved an 18.7% year over year decrease
in these two expense categories.
Hearing panel costs increased again year over year for FY 2010. However, these costs
are recovered through the use of fine monies accumulated in the MFDA’s Discretionary
Fund. As a result, Hearing Panel costs have no impact on the MFDA’s revenues over
expenses position.
26 Mutual fund dealers association of canadaDeficiency of Revenue over Expenses
The MFDA ended FY 2010 with a deficiency of revenues over expenses of $949,811
(compared to a deficiency of $1,504,949 for FY 2009). The MFDA budgeted a deficit
of $1,317,741 for FY 2010. The combination of higher than anticipated revenues and
lower than expected employee related expenses constituted the bulk of the variance. The
deficit for FY 2010 would have been reduced further were it not for the MFDA incurring
$679,000 in legal fees pertaining to the BCSC hearing matter.
MFDA Discretionary Fund
This Fund is an internally restricted fund established by the MFDA Board of Directors
to receive monies from the collection of enforcement fines and the surrender of profits
imposed by order of an MFDA hearing panel. For FY 2010 the fund received fines
of $370,500 (compared to $477,500 for FY 2009) and investment revenue of $5,303
(compared to $19,197 for FY 2009). The Discretionary Fund ended the year with a
balance of $909,085 at June 30, 2010 (compared to $972,093 at June 30, 2009).
MFDA Investor Protection Corporation
The MFDA bills and collects assessments by the MFDA IPC. These amounts flow
through the Statements of financial position as an asset to reflect the assessment to be
received from Members. An offsetting liability to the MFDA IPC accounts for future
remittances due from the MFDA. For the period from July 1, 2009 to June 30, 2009 the
MFDA billed $5,030,220 to its Members on behalf of the MFDA IPC. $58,109 relating to
IPC assessments remained due to the IPC as of June 30, 2009.
Outlook for Fiscal 2011
Expenses for FY 2011 are projected to be $29.0 million with several factors accounting
for the year over year increase. The budget for FY 2010 was formulated subsequent
to the 2008-09 market collapse that created significant challenges for our Members.
In recognition of these challenges and in order to mitigate a fee increase for FY 2010,
the MFDA implemented significant budget cuts, as previously mentioned. These cuts
however, could not practically be maintained going forward without jeopardizing the
investment that the MFDA has made in its staff or impairing the organization’s ability
to effectively deliver upon its regulatory mandate. Consequently, in order to mitigate
the risk of significant employee turnover and to ensure that staff members remain
adequately trained to fulfill our regulatory mandate, the MFDA will see increases in
employee related expenses and training costs for FY 2011. Fortunately, Member AUA
has recovered to support a return to a normalized budget.
Mutual fund dealers association of canada 27In response to the request of the CSA and based upon workload demands, the MFDA will be expanding
its staff complement in the Calgary office, increasing to 14 staff members from last fiscal year’s budgeted
11 positions. The additional staffing has been accommodated through inter-office transfers and the
addition of only one new position for FY 2011. To accommodate the additional staff, the Calgary office will
be expanded within its current location. No other office expansions are planned for FY 2011. A further net
new administrative position is planned for the Enforcement group to address increased workload in the
Litigation department.
Over the past few years, the MFDA has subsidized Member fees through the use of its unrestricted net
asset fund. The effect of these subsidies, totaling $5.45 million since 2006, was to lower Member fees
and mitigate fee increases. It has been the intention of the MFDA to maintain its unrestricted net asset
fund at 25% of yearly operating expenses, representing three months of operating costs. In the absence of
significant year end surpluses, this fund has been depleted to approximately 11% of yearly expenses or less
than 1.3 months of operating costs. Consequently, the MFDA was unable to use this fund as it has in
past years to subsidize membership fees for the 2011 fiscal year. Going forward, it will be necessary to
budget for the gradual replenishment of the unrestricted net asset fund in order to return it to a fiscally
prudent level.
A rewrite of the Electronic Filing System (“EFS”) is scheduled to take place in FY 2011. EFS was launched
in October 2003 and is used by MFDA Members and Financial Compliance staff for the monthly and
annual processing of the Financial Questionnaire and Report. Development of this system was deferred
for the past four years as other budget considerations took priority. However, with this system having now
reached its technical end-of-life and with reporting changes driven by the introduction of IFRS to take
effect in 2011, a rewrite of EFS is now necessary.
Similarly, further development of the Members-only section of the MFDA’s website will occur throughout
the 2011 fiscal year. This development is to further the goal of making it easier for Members to update
their MFDA membership data, improve Member communication methods and provide Members with
comparative risk information.
The 2009-11 Strategic Plan for the MFDA calls for a strong element of industry consultation and
the MFDA will continue efforts in that regard through creating enhanced awareness among our
membership of policy development initiatives and the sourcing of active participation and feedback
of Members in that process.
The MFDA has an accrued employee benefit plan liabilities of $3,332,900. This amount is comprised of a
$1,615,600 registered pension plan liability and a $1,717,300 liability with respect to the post-retirement
benefits plan. The post-retirement benefits plan is an unfunded obligation. Based upon actuarial analysis,
funding for the registered pension plan is planned to occur at a rate of approximately $1,300,000 annually.
Finally, with respect to IFRS, as a not-for-profit organization, the MFDA is not required to adopt IFRS
and so adoption would be on a voluntary basis. The MFDA has determined that the costs associated with
adopting IFRS outweigh the benefits of providing IFRS compliant financial statements. Accordingly,
the MFDA has elected not to adopt IFRS and will continue to follow the Section 4400 series standards
in the CICA Handbook that are currently undergoing further revision by the Canadian Institute of
Chartered Accountants.
28 Mutual fund dealers association of canadaManagement’s Responsibility
for Financial Reporting
The accompanying financial statements and all other information contained in this
Annual Report are the responsibility of MFDA management. The financial statements
have been prepared in accordance with Canadian generally accepted accounting
principles (“GAAP”) and necessarily include some amounts based on the estimates
and judgments of management.
In discharging its responsibilities for the integrity and reliability of the financial
statements, management maintains and relies upon a system of internal controls. These
internal controls are designed to ensure that transactions are properly authorized and
recorded, assets are safeguarded against unauthorized use or disposition and liabilities
are recognized. The MFDA also maintains formalized policies and procedures and
an organizational structure that segregates duties. The MFDA employs standards
and procedures for hiring employees who are required to abide by a business code of
conduct and receive ongoing training regarding the proper execution of their duties.
Mechanisms also exist that enable reporting to the Audit & Finance Committee of any
perceived unethical behavior by employees.
In order to provide their opinion on the MFDA’s financial statements, Deloitte & Touche
LLP reviews the MFDA’s system of internal controls and conducts such tests and other
audit procedures that they consider appropriate. The auditors also meet in-camera with
the Audit & Finance Committee, without management present, to discuss the results of
their work. The independence of the auditors as well as the effectiveness of their work is
assessed by the Audit & Finance Committee annually.
The Audit & Finance Committee reviews the effectiveness of the company’s financial
reporting and internal control systems, any significant financial reporting issues,
the presentation and impact of significant risks, and key estimates and judgments
of management that may be material for financial reporting purposes. Additionally,
the Audit & Finance Committee meets periodically with MFDA management and the
auditors, and reports to the Board of Directors thereon. The Audit & Finance Committee
also reviews the annual financial statements and recommends them for approval by the
Board of Directors.
The accompanying financial statements have been audited by the auditors who are
engaged by the Board of Directors on the recommendation of the Audit & Finance
Committee. The appointment of the auditor is ratified at the Annual General Meeting
of MFDA Members.
Larry M. Waite Paul Reid
President & Chief Executive Officer Director, Finance & Administration
Mutual fund dealers association of canada 29You can also read
