Strategy
EXCLUSIVE: Phase Two Of Canada's Client Relationship Model Is "A Real Sea Change"

A range of industry figures working in the Canadian wealth management sector recently explained regulatory changes designed to make the sector more open, mirroring developments in countries such as the UK.
Equipos, a provider of
private client reporting technology and communication tools,
rolled out an educational initiative earlier this month to help
Canadian firms understand changes brought about by phase two of
the Client Relationship Model, effective this July.
The aim of CRM is to enhance investor protection in Canada
through improved relationship disclosure, conflict management,
and suitability and account performance reporting. Phase 2, known
as CRM2, is focused on enriching investors’ understanding of the
cost and performance of their investments.
Co-sponsored by WealthBriefing, the programme launched
on 9 April with a webinar during which panellists walked through
the details of CRM2.
Mike Hendy, vice president of North America at Equipos, moderated
the webinar, which also featured: Drew Brown, associate vice
president at TD
Wealth; Rebecca Cowdery, partner at Borden Ladner
Gervais; Karim Manaa, partner at Deloitte; and Grace McSorley,
executive director of business risk, regulatory affairs and
governance at CIBC.
By way of background, Canadian buy-side investment management
firms will - as required by the Canadian Securities
Administrators - have to provide pre-trade disclosure of charges
and disclose their compensation from debt transactions in trade
confirmations as of July 15, 2014.
Next year, enhancements to client statements will be introduced,
while in 2016 firms will be required to produce annual reports on
charges and other compensation, as well as an annual investment
performance report.
Andre Fok Kam, a consultant to the securities industry in Canada,
told this publication that the main beneficiary of CRM should be
retail investors who will be better able to evaluate the costs
and benefits of using an advisor.
“Although advisors’ initial response to CRM2 was rather less than
enthusiastic, they are beginning to wake up to the marketing
opportunities it provides. There is a growing body of evidence
that investors who use advisors have better returns than those
who don’t. The mandatory disclosure of personal rates of returns
will help quantify that gap,” he said.
But, ultimately, it will be up to advisors to demonstrate the
value of their advice.
Expect questions
Hendy kicked off the webinar by asking Cowdery to outline exactly
what CRM2 is and whom it will impact.
The first stages of CRM - which are already effective - were
“more modest,” Cowdery said.
The central concept was that firms should explain in writing to
their clients what kind of services they can expect to receive
from their advisors. Requirements included ensuring that products
recommended were suitable, as well as rules on managing conflicts
of interest.
“But with CRM2, what we have seen is a real sea change,” she
said.
“Perhaps the biggest change that will affect so many people in
the Canadian financial services industry is the pre-trade
disclosure, which can be given orally by advisors to their
clients before any trade goes through,” Cowdery continued.
Next year will bring additional requirements for account
statements but 2016 “will be our big year,” with the annual
reports coming into effect, she said.
As a result, Manaa anticipates that clients will ask a lot of
questions about costs and performance because “this is really the
major change they will see with respect to their statements.”
With CRM2 increasing transparency, they may ask for a breakdown
of fees, for example.
In terms of performance, CRM2 requires a dollar-weighted rate of
return rather than the traditional time-weighted method, which
may confuse clients who are used to calculating their returns in
a certain way.
They will probably ask why it is different and what has changed,
Manaa said. “There is a lot of work that needs to be done…to
explain and provide all the answers.”
Likewise, Brown believes that the information CRM2 is requiring
will make financial statements “a lot more relevant” to clients
and in turn drive more questions.
Culture change
McSorley said CIBC is “welcoming all the changes” brought about
by CRM2. Transparency is “very good for the industry” and will
help clients understand what they’re paying for, she said.
Cowdery noted that understanding the aims of CRM2 will enhance
the customer experience while also minimising misunderstandings
between the client and the firm.
On the other hand, as McSorley highlighted, many advisors are
already CRM2-compliant, in some respects, as they have fee-based
accounts and thus disclosing such information is already part of
their work culture.
“For other people this will be a change of management experience
and so we are working on very tactical education,” McSorley
said.
There is of course a great need to equip investment advisors with
the language and ability to explain some of the new concepts to
clients because “it’s not simple,” she added.
Hendy asked Brown about the physical challenges of compliance, in
terms of reporting and collecting data, for instance.
“Probably the biggest challenge within TD Wealth is that we
actually have seven lines of business all needing to comply with
the regulation, all with different books or records and perhaps
different gaps that exist for CRM2,” Brown said.
From a reporting perspective, Brown said CRM2 has provided his
firm with an opportunity to ensure it delivers a “consistent
quality of reporting.”
While technology is a “significant hurdle,” he acknowledged that
it will probably be a challenge for everyone.
The client-advisor relationship
During the webinar, a participant asked how CRM2 will affect the
client-advisor relationship, in response to which McSorley said
it will call for a heightened level of dialogue between the
two.
Investment advisors will really have to know the client, she
said. “It is definitely I think the biggest cultural shift for
investment advisors in terms of dealing with their clients.”
However, for some it will be business as usual, she noted.
Hendy concluded the webinar by asking the panellists: “If you had
one piece of advice for the wealth and asset managers in the
audience regarding CRM2, what would it be?”
“The short answer is start early,” said Brown, adding that CRM2
shouldn’t be viewed purely as a compliance exercise.
He warned that the various changes should be approached as a
whole - as a programme not a project - rather than tackling the
new rules individually. The initiatives for 2015 and 2016, for
example, are the bigger pieces of the puzzle.
McSorley agreed with Brown that starting early is paramount. She
also advised to “communicate often” – at both the advisor and
client level – while equipping advisors with the tools they need
to effectively explain the changes.
In the words of Cowdery, CRM2 “really does have to be embraced at
the client service level.”
She also emphasised the importance of thinking about CRM2 in the
wider context of regulatory initiatives focused on ensuring that
retail clients understand what they’re investing in.
“If it’s done properly I think it will bolster the Canadian
financial services industry,” she said.