Go Directly to the FAQ's
	See May 1, 2001 Update
	See January 7, 2003 Update

General

1. When do the requirements come into effect?
   
2. Where can I find the actual text of the Rule?
   
3. Where can I find a summary of the key compliance dates?
   
4. Has the text of the Rule been finalized?
   
5. Does the Rule apply to all financial planners?
   
6. What do I need to do if I am a salesperson of a registered firm that uses a restricted title and service description but I am not qualified?
   
7. Can I still deal with my clients after the Rule takes effect?
   
8. I am an employee of a registrant and I am providing financial planning advice to firm clients, but I an not registered to trade or advise, nor am I engaged in any registerable activity, e.g. I am not acting in furtherance of trades. Do I now have to be registered?
   
9. What should a firm do to prepare to comply with the Rule?
   
   
   

FPPE Grandfathering Exemptions

1. How can I find out whether my program is grandfathered from the FPPE requirement?
   
2. Am I eligible for a grandfathering exemption if I hold the CFP designation?
   
3. I will complete one of the courses included in the list of grandfathering exemptions during 2001 and I also intend to write the CFP Professional Proficiency Examination during 2002. Do I have to wait until I pass that examination in order to be grandfathered from the FPPE requirement?
   
4. What is the last date for being enrolled in a grandfathered program in order to be eligible for an exemption from the FPPE?
   
5. What is the last date for completing a grandfathered program in which I am enrolled on March 31, 2001?
   
6. I am working towards a CFP designation. I am currently enrolled in a course that is one of the FPPE grandfathering criteria. Can I switch from my present FPPE grandfathered course to a different one after March 31, 2001?
   
7. If I am eligible for an FPPE grandfathering exemption, what do I need to do to ensure that I am grandfathered from passing the FPPE?
   
8. If my program is one of the FPPE grandfathering criteria, am I also exempt from the two year registration or licensing requirement?
   
9. If my program is one of the FPPE grandfathering criteria, do I need to satisfy the two year registration or licensing requirement by March 31, 2004 in order to be grandfathered from passing the FPPE?
   
10. Can I lose my FPPE grandfathering exemption if I file the Notice by March 31, 2004?
    
11. I currently work in the financial planning department of a full service dealer, but I am not registered or licensed. Is my employer able to rely on my eligibility for a grandfathering exemption and hold me out to clients as a financial planner?
    
12. I currently work in the financial planning department of a financial services corporation that is not a registrant and I am not registered or licensed. The company is not caught by the rule. I want to do the same work in the financial planning department of a different registered employer in five years. Is my new employer able to rely on my eligibility for a grandfathering exemption in holding me out as a financial planner?
    
13. I am a financial planner registered to sell mutual funds in a Montreal branch of a Canadian bank, having completed all of the requirements under the Quebec legislation. If I am transferred to a Toronto branch in 2005 to continue the same work and file a Notice on Form 33-107F1 stating that I am eligible for a grandfathering exemption, will I be exempt from writing the FPPE?
    
    
    

Exemptions from the Experience Requirement

1. What type of information should be provided by someone seeking an exemption from the two year experience requirement?
   
2. Who do I apply to for the exemption?
   
3. How much does it cost to apply for an exemption?
   
   
   

Continuing Education Requirement

1. Which organizations' continuing education regimes will be approved?
   
2. How do I satisfy the continuing education requirement if I do not belong to an organization that imposes on me a continuing education requirement relating to financial planning?
   
   
   

The Title Pools

1. What is meant by the phrase "restricted titles and service descriptions "?
   
2. Which titles are created by the restricted title pools?
   
3. What about providing services?
   
4. If my firm distributes marketing brochures that refer to financial security, retirement income or financial advice would they be holding themselves out as providing restricted services for purposes of the rule? Would my firm be holding me out as offering a restricted service simply because I am a registered salesperson of that firm?
   
5. How can I determine whether a title or firm name is similar to "financial planner"?
   
6. I'm registered to sell securities. If I say I'm a "securities adviser" am I caught by the Rule?
   
7. I'm registered to sell securities. If I say I'm a "mutual fund planner" am I caught by the Rule?
   
   
   

Scope

1. How would I become subject to the requirements?
   
2. How does my firm become subject to the requirements?
   
3. What are some examples of holding out using a restricted title?
   
4. What are some situations where a firm or individual might be holding themselves out using a restricted service description?
   
5. Would I be holding myself out using a restricted title if I put on my business card that I am a member of the Canadian Association of Financial Planners or CAFP? What about showing my membership in the Canadian Association of Insurance and Financial Advisors or CAIFA?
   
6. I am registered as a salesperson of a mutual fund dealer. Neither I nor my firm hold ourselves out in the manner specified in the Rule or prepare financial plans. However, the advice I give to my clients when selling them securities includes many of the domains set out for the FPPE. Are my firm and I subject to the Rule's proficiency requirements?
   
7. Do the requirements apply to institutional sales representatives?
   
8. Would I be subject to the requirements if I pay someone else to prepare financial plans for my clients?
   
9. Could I attend the sessions between the person who prepares the financial plans and my clients?
   
10. Could someone be at arm's length with me even though I refer all my clients to him?
    
    
    

Requirements for Individuals

1. What are the requirements that an individual must satisfy?
   
2. Do I need to complete any particular course?
   
   

Requirements for Firms

1. What are the requirements that a firm must satisfy?
   
2. How many individuals at the firm must satisfy the requirements?
   
3. Must the individuals at the firm who satisfy the requirements on behalf of the firm be registered?
   
4. Are persons at the firm who have not satisfied the requirements permitted to participate in the preparation of financial plans?
   
5. I want my new employees to write the FPPE and then gain experience by putting what they know to use by working with clients . How can they do this if they first need two years experience as a registrant or licensee?
   
6. We are a bank that owns a registered mutual fund dealer, which has a subsidiary that manages a family of proprietary mutual funds. The mutual fund dealer is operationally integrated into the bank. Some bank employees who engage in loan and deposit transactions on behalf of clients also are registered to sell mutual funds. A lot of our corporate promotional material mentions the financial advisory services that traditionally have been provided by financial institutions. If we make a reference in the material to retirement planning or wealth or asset management, do all employees of the mutual fund dealer who deal with the public have to pass the FPPE?
   
7. We are a bank that owns a registered mutual fund dealer, which has a subsidiary that manages a family of proprietary mutual funds. The portfolio managers who manage the funds are specifically exempt from the proficiency requirements. The portfolio managers sometimes speak at public seminars about the funds and the mutual fund dealer, but they hold themselves out as portfolio managers, not as providers of any restricted services. Would the portfolio managers lose their exemption because the would be considered to be holding themselves out to clients as providing restricted services and not confining their activities to discretionary portfolio management?
   

Writing the Financial Planning Proficiency Examination (FPPE)

1. When will I have a chance to write the FPPE before the requirements come into effect?
   
2. Who do I contact to sign up for the FPPE?
   
3. Where can I write the FPPE?
   
4. How much will it cost to write the FPPE?
   
5. How long does it take to write the FPPE?
   
6. Do I need to bring anything with me when I write the FPPE?
   
7. How do I find out what the questions on the FPPE will be like?
   
8. What should I study to prepare for the FPPE?
   
9. What is the relationship between the FPPE and the CFP Professional Proficiency Examination?
   
10. What is the pass mark on the FPPE?
    
11. How long will I need to wait for the results?
    
    

Notice

1. What is the deadline for filing the Notice if I am not eligible for a grandfathering exemption?
   
2. What is the deadline for filing the Notice if I am eligible for a grandfathering exemption?
   
3. If I am registered as a mutual fund dealer and also have a license as a life agent, to whom do I send the Notice?
   
4. Do I need to file the Notice every year?
   
5. Where can I find the different forms of the Notice?
   
   

Applicability Across Canada

1. If I live in a province which does not impose the FPPE and other proficiency requirements, but I send financial plans by email to my clients in a province which requires the FPPE, am I subject to the FPPE and other proficiency requirements?
   
2. If I write the FPPE while working in Ontario and then move to another Canadian province, will I need to write another examination?
   

General

1. When do the requirements come into effect?

The effective date of the Rule is February 15, 2002. Full compliance generally will be required as of February 15, 2002. Click here for a compliance time line.

After that date an individual who is registered or licensed and continues to use the restricted titles or service descriptions must have passed the Financial Planning Proficiency Examination (FPPE) or met the grandfathering criteria and also satisfy the experience and continuing education requirements. The same applies if the individual provides customers with a document entitled "Financial Plan". If a registered firm continues to use the restricted titles or service descriptions, or provide clients with documents entitled "Financial Plan", the services and plan must be provided by a qualified employee, officer or agent.

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2. Where can I find the actual text of the Rule?

Click on the links below for the text of the proposed and final versions of the Rule and to read the Notices that the OSC published at the same time as these versions of the Rule.

• The final version of the Rule is 33-107, February 16, 2001 in PDF
• The version of the Rule published for comment, December 3, 1999 in PDF  

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3. Where can I find a summary of the key compliance dates?

Click here for a time line.

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4. Has the text of the MI 33-107 Rule been finalized?

The Rule was delivered to the Ontario Minister of Finance on February 15, 2001. The Minister has 60 days to reject the Rule or return it to the OSC for further consideration. The same applies to the text of the Notices to be filed with the OSC and other regulators. The responses we are providing are based on the text that was sent to the Minister.

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5. Does the Rule apply to all financial planners?

The Rule applies only to firms and individuals registered under the Ontario Securities Act. Under a proposed regulation, the same proficeincy regime will apply to licensed life agents under the Ontario Insurance Act. The Rule adds a new condition of registration. Registered firms and individuals must satisfy the Rule's requirements if they hold themselves out using specific titles, business names or service descriptions. These terms have been chosen because in the view of the regulators they would generally convey to consumers objective, comprehensive, integrated financial advice tailored to an individual's present and future circumstances.

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6. What do I need to do if I am a salesperson of a registered firm that uses a restricted title and service description but I am not qualified?

That will depend on how your firm decides to manage its compliance with the Rule. If it advertises (i.e. holds itself out as providing) the restricted services, it must deliver them through a qualified individual. If your firm wants to provide them through you, it may expect you to satisfy the Rule's requirements. On the other hand, your firm may have you join a team that includes a qualified person who is responsible for delivering the advertised services to your clients. The firm would then require you to clarify to your clients that you are not holding yourself out as providing the services described in the Rule. The firm might also need to alter its promotional material to clarify that it is not holding out all its employees and agents to customers using restricted titles or as providing restricted services.

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7. Can I still deal with my clients after the Rule takes effect?

Yes, in accordance with the other terms and conditions of your registration or licensing. However, unless you have passed the FPPE or are grandfathered, you cannot hold yourself out to your clients under a restricted title, offer the restricted services to them on behalf of the firm, or provide them with documents entitled "Financial Plan".

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8. I am an employee of a registrant and I am providing financial planning advice to firm clients, but I an not registered to trade or advise, nor am I engaged in any registerable activity, e.g. I am not acting in furtherance of trades. Do I now have to be registered?

No. The Rule does not create a new registration category for financial planners. However, it requires registered firms to deliver financial planning services through an employee or agent who meets the prescribed proficiency standard. So if your firm is caught by the Rule and chooses to continue to deliver financial planning services through you, you must pass the FPPE or be grandfathered, and also meet the two year experience and continuing education requirements even though you are not registered yourself.

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9. What should a firm do to prepare to comply with the Rule?

1. Put together a list of employees who already satisfy the requirements.
2. Put together a list of additional employees who would need to satisfy the requirements in their current roles. Determine which of them could satisfy the requirements by February 15, 2002 by writing the FPPE or applying for an exemption from the two year experience requirement. For the other employees, determine the changes needed in their titles or roles so that they are no longer subject to the requirements.
3. Determine whether the firm has an adequate number of employees who have satisfied the requirements. No specific number is required, but client service must be taken into account.
4. Ensure that teams within the firm are set up in a way that satisfies the requirements.
5. Review the firm's marketing materials for compliance, such as in descriptions of services provided. Check both hard copy and material on the firm website.

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FPPE Grandfathering Exemptions

1. How can I find out whether my program is grandfathered from the FPPE requirement?

Consult the list in the Rule itself or Notice form required to be filed by everyone who relies on a grandfathering exemption (click here for Form 33-107F1) All programs proposed to be grandfathered in the draft published for comment in December 1999 are still proposed to be grandfathered.

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2. Am I eligible for a grandfathering exemption if I hold the CFP designation?

It depends on how you received the CFP designation. Designations such as the CFP are not in themselves the basis for an exemption from passing the FPPE. However, during the transitional period you would be eligible for FPPE grandfathering if you passed the CFP Professional Proficiency Examination of the Financial Planners Standards Council (FPSC). Alternatively, most of the courses of study that constitute FPPE grandfathering criteria under the Rule also are part of the CFP requirements.

We expect that most people who have obtained the CFP designation, including those who were grandfathered into the CFP designation by the FPSC, will find that they are already covered under one or more of the FPPE grandfathering criteria, and of course only one is necessary. Individuals who obtain the CFP designation prior to March 31, 2003 will necessarily be meeting one or more of the FPPE grandfathering criteria, and so they would not be required by the Rule to write the FPPE.

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3. I will complete one of the courses included in the list of grandfathering exemptions during 2001 and I also intend to write the CFP Professional Proficiency Examination during 2002. Do I have to wait until I pass that examination in order to be grandfathered from the FPPE requirement?

No. Satisfying any one of the grandfathering criteria is sufficient. Satisfying a second one at a later date does not affect your eligibility for grandfathering.

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4. What is the last date for being enrolled in a grandfathered program in order to be eligible for an exemption from the FPPE?

March 31, 2001. Individuals should retain an official record of the date of their enrollment, at least if recently enrolled.

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5. What is the last date for completing a grandfathered program in which I am enrolled on March 31, 2001?

March 31, 2003, except for the pre-1995 version of the Chartered Life Underwriter program, which must be completed by March 31, 2002.

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6. I am working towards a CFP designation. I am currently enrolled in a course that is one of the FPPE grandfathering criteria. Can I switch from my present FPPE grandfathered course to a different one after March 31, 2001?

You will be exempt from the FPPE if you complete one of the prescribed FPPE grandfathering courses or write one of the prescribed exams by March 31, 2003. You must, however, be enrolled by March 31, 2001 in the particular course you will rely on for grandfathering to be exempt from the FPPE. You can't switch and still be grandfathered. However, the CFP designation requires an exam, and this exam is a separate FPPE grandfathering criterion, so you could switch courses, but still be FPPE grandfathered if you passed the FPSC's exam by March 31, 2003.

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7. If I am eligible for an FPPE grandfathering exemption, what do I need to do to ensure that I am grandfathered from passing the FPPE?

You need to file a prescribed Notice on Form 33-107F1, Form 33-107F2, Form 33-107F3, no later than March 31, 2004. If you are engaged in any of the restricted activities before that date, click here for the deadline.

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8. If my program is one of the FPPE grandfathering criteria, am I also exempt from the two year registration or licensing requirement?

No. The grandfathering exemptions apply only to the requirement to write the FPPE. They do not provide an exemption from the two year experience requirement or the continuing education requirement.

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9. If my program is one of the FPPE grandfathering criteria, do I need to satisfy the two year registration or licensing requirement by March 31, 2004 in order to be grandfathered from passing the FPPE?

Yes. Unless you have satisfied the two year registration or licensing requirement by March 31, 2004, you will be unable to file the Notice by the deadline. However, you should keep in mind that this requirement could be satisfied either by being registered or licensed for two years or by satisfying the regulator that you have equivalent qualifications.

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10. Can I lose my FPPE grandfathering exemption if I file the Notice by March 31, 2004?

No.

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11. I currently work in the financial planning department of a full service dealer, but I am not registered or licensed. Is my employer able to rely on my eligibility for a grandfathering exemption and hold me out to clients as a financial planner?

Yes. However, your employer must file it's Notice indicating that it is providing the restricted services through you and others before the end of the grandfathering period.

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12. I currently work in the financial planning department of a financial services corporation that is not a registrant and I am not registered or licensed. The company is not caught by the rule. I want to do the same work in the financial planning department of a different registered employer in five years. Is my new employer able to rely on my eligibility for a grandfathering exemption in holding me out as a financial planner?

No. Neither you nor your new employer would be able to use your current eligibility for a grandfathering exemption due to the fact that a Notice was not filed in respect of you by March 31, 2004. You would have to write the FPPE. However if you were listed in a Notice filed by a registered employer by March 31, 2004, you would be in the same position as an individual registrant who was required to file a Notice. Just like a registered individual, you would be able to carry your grandfathered status over to a new employer.

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13. I am a financial planner registered to sell mutual funds in a Montreal branch of a Canadian bank, having completed all of the requirements under the Quebec legislation. If I am transferred to a Toronto branch in 2005 to continue the same work and file a Notice on Form 33-107F1 stating that I am eligible for a grandfathering exemption, will I be exempt from writing the FPPE?

No. Form 33-107F1 will not be accepted for filing after March 31, 2004. You will have lost the grandfathering exemption and will be required to pass the FPPE.

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Exemptions from the Experience Requirement

1.What type of information should be provided by someone seeking an exemption from the two year experience requirement?

• The nature of any experience you have relating to the financial services industry (e.g., accounting, banking, teaching, preparing financial plans on a fee for service basis). You should state whether the experience involves contact with clients who are investors, and experience operating in a regulated environment.
• The length of time you have had that experience. Generally you would be expected to have two years of experience.
  

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2. Who do I apply to for the exemption?

All securities and insurance regulators with which you are registered or licensed if your activities in the jurisdiction will subject you to the requirements. Your application should indicate which other regulators are receiving your application. We would suggest you prepare a single application addressed to all of the applicable regulators and send it to each one at the same time.

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3. How much does it cost to apply for an exemption?

That depends on the regulator to which you apply for the exemption. There is no fees for these applications to the Ontario Securities Commission.

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Continuing Education Requirement

1. Which organizations' continuing education regimes will be approved?

Based on discussions we have had so far, we anticipate approving the following:

The Investment Funds Institute of Canada
The Investment Dealers Association of Canada
The Canadian Association of Insurance and Financial Advisers
The Institute of Canadian Bankers

These organizations have been working towards harmonizing their requirements, tentatively based on 90 hours over three years. We plan to consider the continuing education requirements of other organizations before the Rule's effective date.

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2. How do I satisfy the continuing education requirement if I do not belong to an organization that imposes on me a continuing education requirement relating to financial planning?

When you file the required notice, you will have an opportunity to undertake to comply with one of the approved continuing education regimes. The choice of which one is up to you.

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The Title Pools


1. What is meant by the phrase "restricted titles and service descriptions "?

The rule is based on a holding out test. There are two pools of words. Any combination of words drawn from both pools that occurs in a business title, firm name or service description triggers the financial planning proficiency requirements for a registered individual or firm that uses them.

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2. Which titles are created by the restricted title pools?

Any title containing the word "planner" or combining a word from the left column below with a word in the right column.

Scope


1. How would I become subject to the requirements?

By doing any of the following:

• Holding yourself out using one of the titles in the restricted pools.
  
• Holding yourself out as providing services described by an expression in the restricted pools.
  
• Providing a document having the expression "financial plan" in its title to a client.
  

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2. How does my firm become subject to the requirements?

By doing any of the following:

• Holding out itself or any of its officers, employees or agents using one of the titles in the restricted pools.
  
• Holding out itself or any of its officers, employees or agents as providing services described by an expression in the restricted pools.
  
• Providing a document having the expression "financial plan" in its title to a client.
  

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3. What are some examples of holding out using a restricted title?

• Using a title on a business card.
  
• Using a title in a newspaper advertisement.
  
• Using a title on a sign.
  
• Using a title in promotional material.
  
• Using a title in speaking to potential clients at a seminar.
  

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4. What are some situations where a firm or individual might be holding themselves out using a restricted service description?

• Content of brochures provided to potential clients.
  
• Description of services on a web site.
  
• An interactive financial plan prepared on a web site that someone would then bring to a firm for an individual analysis.
  
• Advertising in media such as newspapers or television.
  

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5. Would I be holding myself out using a restricted title if I put on my business card that I am a member of the Canadian Association of Financial Planners or CAFP? What about showing my membership in the Canadian Association of Insurance and Financial Advisors or CAIFA?

Yes, in the case of the Canadian Association of Financial Planners. No, in the case of the Canadian Association of Insurance and Financial Advisors because the title "insurance adviser" is not restricted. Someone who indicates they are a member of CAIFA could just as easily be holding themselves out as an insurance adviser as a financial adviser. Since the association title includes an unrestricted title as well as a restricted title, the holding out test is not met.

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6. I am registered as a salesperson of a mutual fund dealer. Neither I nor my firm hold ourselves out in the manner specified in the Rule or prepare financial plans. However, the advice I give to my clients when selling them securities includes many of the domains set out for the FPPE. Are my firm and I subject to the Rule's proficiency requirements?

No. The coverage of the Rule is based on a holding out test, i.e. the words you use to describe yourself or to describe the services you are offering to potential clients, not on an assessment of the type of advice you actually provide.

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7. Do the requirements apply to institutional sales representatives?

Registrants whose clients are not individuals are exempted from the requirements. The competencies tested by the FPPE relate to the ability to assess an individual's financial situation and are not generally relevant to institutional selling.

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8. Would I be subject to the requirements if I pay someone else to prepare financial plans for my clients?

No, so long as:

• The person you pay obtains the information for preparing the plan directly from your client.
  
• The person you pay delivers the plan directly to your client.
  
• You and the person you pay are dealing at "arm's length".
  
• The compensation arrangement is disclosed to your client.
  

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9. Could I attend the sessions between the person who prepares the financial plans and my clients?

Yes.

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10. Could someone be at arm's length with me even though I refer all my clients to him?

Yes. For the actual definition of arm's length for this purpose, you should refer to the Income Tax Act.

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Requirements for Individuals


1. What are the requirements that an individual must satisfy?

• Pass the FPPE
  
• Two years of securities registration or licensing as a life agent.
  
• Undertake to comply with an approved continuing education regime if you are not subject to one already.
  

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2. Do I need to complete any particular course?

There is no requirement to take a particular course. However, it is expected that to pass the FPPE you will most likely need to complete a financial planning program comparable to those for which there are grandfathering exemptions.

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Requirements for Firms


1. What are the requirements that a firm must satisfy?

• If the requirements apply because of the manner in which the firm holds out an individual, the individual must satisfy the requirements for individuals.
  
• If the requirements apply because the firm provides documents having a title that includes the expression "financial plan" to clients, the documents must be provided on its behalf by, or on the instructions of, individuals who satisfy the requirements for individuals.
  
• If the requirements apply because of the manner in which the firm holds itself out, the firm must provide the indicated services and use an individual who satisfies the requirements for individuals to do so.
  

For any particular firm, any or all of these requirements could apply.

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2. How many individuals at the firm must satisfy the requirements?

There is no predetermined minimum number. The number needs to be sufficient to satisfy the needs of the firm's clients. It will vary according to the size of the firm and the services provided by the firm.

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3. Must the individuals at the firm who satisfy the requirements on behalf of the firm be registered?

No. There is no requirement that they be registered if their role at the firm does not otherwise require them to be registered.

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4. Are persons at the firm who have not satisfied the requirements permitted to participate in the preparation of financial plans?

Yes, so long as the plans are provided by, or on the instructions of, individuals who have satisfied the requirements. For example, a person who has not satisfied the requirements could assist in the preparation of a plan. A dually licensed mutual fund salesperson / life agent who will be responsible for implementing a financial plan might attend a meeting at which the plan is explained to the client by the person who prepared the plan and satisfies the requirements.

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5. I want my new employees to write the FPPE and then gain experience by putting what they know to use by working with clients . How can they do this if they first need two years experience as a registrant or licensee?

Nothing in the rule would preclude these employees from helping to provide financial planning advice to clients under supervision, so long as a qualified person also dealt with the client and took responsibility for the advice. The new employees could not use restricted titles, nor be held out by the firm as providing the restricted services on their own. This approach would also allow a team of individuals with varying backgrounds to deal with a client, so long as a qualified person was part of the team and took responsibility for the advice delivered under a restricted title or service description.

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6. We are a bank that owns a registered mutual fund dealer, which has a subsidiary that manages a family of proprietary mutual funds. The mutual fund dealer is operationally integrated into the bank. Some bank employees who engage in loan and deposit transactions on behalf of clients also are registered to sell mutual funds. Our corporate promotional material mentions the financial advisory services that traditionally have been provided by financial institutions. If we make a reference in the material to retirement planning or wealth or asset management, do all employees of the mutual fund dealer who deal with the public have to pass the FPPE?

No. If the your brochure is drafted in such a way that it would lead customers to expect that the restricted services are provided by a registered firm or by registered individuals included in the corporate group, then they meet the holding out test. The promoted services must be provided by the registered firm to the client by a qualified person, but not all employees of a registered firm that uses a restricted title in its firm name or are held out using a restricted service description need to be qualified. However, registered employees that use a restricted title themselves, all employees that are held out by the registered firm as providing the restricted services and all employees through whom it provides the restricted services must be qualified.

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7. We are a bank that owns a registered mutual fund dealer, which has a subsidiary that manages a family of proprietary mutual funds. The portfolio managers who manage the funds are specifically exempt from the proficiency requirements. The portfolio managers sometimes speak at public seminars about the funds and the mutual fund dealer, but they hold themselves out as portfolio managers, not as providers of any restricted services. Would the portfolio managers lose their exemption because the would be considered to be holding themselves out to clients as providing restricted services and not confining their activities to discretionary portfolio management?

No. Even if the registered mutual fund dealer would be caught by the use of the restricted service descriptions, the individual portfolio managers would be using their own titles and not holding themselves out as providing restricted services. The registered dealer would have to make sure that the financial planning services were provided by a qualified individual or by a team that includes a qualified individual who has contact with the client and takes responsibility for the financial planning and similar advice.

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Writing the Financial Planning Proficiency Examination (FPPE)


1. When will I have a chance to write the FPPE before the requirements come into effect?

The current industry recommendation is that the FPPE be given this year in September 2001 and again in early December 2001. Click here for a time line.

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2. Who do I contact to sign up for the FPPE?

The administrative structure for the FPPE is not yet in place. However, if you might want to write the FPPE, please e-mail your firm name and address to tleonard@osc.gov.on.ca as this will help give us an idea of the number of people that will be writing. You will have to formally apply to write the FPPE when the dates and locations have been finalized.

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3. Where can I write the FPPE?

The locations where the FPPE can be written have not yet been determined as we need more information as to the number of potential candidates.

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4. How much will it cost to write the FPPE?

This has yet to be determined, as we are still estimating the expenses. The cost will not exceed $350.

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5. How long does it take to write the FPPE?

The FPPE is an all day examination, including a three hour session in the morning consisting of multiple choice questions and a three hour session in the afternoon consisting of case studies in which you must construct and write the answers.

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6. Do I need to bring anything with me when I write the FPPE?

You will need to bring a non-programmable business calculator.

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7. How do I find out what the questions on the FPPE will be like?

When you register to take the FPPE, you will be given a manual, which will contain sample questions. The manual will also list the subject areas tested on the FPPE and the approximate percentage weights given to each area. The FPPE questions are designed to test knowledge, understanding, application, analysis and synthesis.

In the meantime, for general information, the current draft of the FPPE Examinee Manual, the Final Report of the National Examination Working Committee on the FPPE are available on the OSC website.

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8. What should I study to prepare for the FPPE?

There is no prescribed set of materials. You might wish to study the materials used for a financial planning program such as those for which grandfathering exemptions are provided. A suitable time to write the FPPE might be when you are just finishing one of those programs.



9. What is the relationship between the FPPE and the CFP Professional Proficiency Examination?

The FPPE will be a regulatory requirement for certain securities registrants and licensed life agents. The CFP Professional Proficiency Examination is required for those who wish to obtain the CFP designation offered by the Financial Planners Standards Council. The two examinations are independent.

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10. What is the pass mark on the FPPE?

The FPPE does not have a preset pass mark. The pass mark will be set by educational and measurement experts based on a statistical analysis of the performance of all the candidates on each question on the exam. This will help ensure that the standard for passing the FPPE does not vary from year to year.

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11. How long will I need to wait for the results?

A reasonable period to assess and distribute results will be determined by a committee of industry educational organizations closer to the date of the examination.

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Notice


1. What is the deadline for filing the Notice if I am not eligible for a grandfathering exemption?

February 15, 2002 if you are using a restricted title or service description or providing documents entitled "Financial Plan" to clients as of that date. If you do not do any of these things until a later date, you must file the Notice before you do them. Click here for a time line.

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2. What is the deadline for filing the Notice if I am eligible for a grandfathering exemption?

Generally the first time after February 15, 2002 that the annual fee on your registration is payable. We expect that the firm will file Notices for all its grandfathered employees and agents at the same time. Click here for a time line.

If you have not yet satisfied all of the requirements by that date, the Notice must be filed before you use a restricted title or service description or provide documents entitled "Financial Plan" to clients. The absolute deadline for filing the Notice if you wish to receive the benefit of an FPPE grandfathering exemption is February 15, 2004 even if you do not intend to engage in any of the restricted activities until a later date.

Nothing, however, would preclude you from filing the Notice form as soon as you comply with the proficiency requirements.

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3. If I am registered as a mutual fund dealer and also have a license as a life agent, to whom do I send the Notice?

The Notice should be sent to all regulators with which you normally deal directly for filings under the Ontario Securities Act, the Ontario Insurance Act or other securities or insurance laws in Canada. For example, if you file information as to a change of address with the Investment Dealers Association of Canada (IDA), file the Notice there as well. If you are regulated by both securities and insurance regulators (such as the OSC and the Financial Services Commission of Ontario), you must file a Notice with each regulator.

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4. Do I need to file the Notice every year?

The normal requirement is that the Notice is filed only once. However, there are circumstances under which you might have to file the Notice more than once. For example, if you move to another province and become a registrant there, you would need to file the Notice with the new regulator. If you are now subject to one of the approved continuing education (CE) regimes by virtue of your membership in an organization and terminate that membership without becoming subject to another organization's CE requirements, you would need to file the Notice or another paper to undertake to be subject to an approved CE regime of your choice.

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5. Where can I find the different forms of the Notice?

Form 33-107F1
Form 33-107F2
Form 33-107F3


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Applicability Across Canada


1. If I live in a province which does not impose the FPPE and other proficiency requirements, but I send financial plans by email to my clients in a province which requires the FPPE, am I subject to the FPPE and other proficiency requirements?

Yes, if you are registered under securities legislation or licensed as a life agent in the province to which you send the plans. Note that if you have a client in Ontario to whom you sell mutual fund or other securities, you are required to be registered under the Ontario Securities Act.

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2. If I write the FPPE while working in Ontario and then move to another Canadian province, will I need to write another examination?

As far as regulatory requirements are concerned, we understand at this point that only Quebec would require a different proficiency examination. Firms and organizations might have their own proficiency requirements.

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