: Primerica Financial Services Ltd - Submission

June 17, 2016

Expert Committee to Consider Financial Advisory
And Financial Planning Policy Alternatives
c/o Frost Building North, Room 458
4th Floor, 95 Grosvenor Street
Toronto, Ontario
M7A 1Z1

To the Members of the Expert Committee:

RE: Preliminary Policy Recommendations of the Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives

Primerica Financial Services (Canada) Ltd. and its related companies (" Primerica") are writing to provide comments on the Financial Advisory and Financial Planning Recommendations.

We have worked closely with the Investment Funds Institute of Canada on their comprehensive submission and we agree with the industry-wide concerns it raises.

We understand the challenging task that regulators have in trying to balance expectations for consumer protection enhancements with the demands of a growing market place with new products. In this regard, with various business models used within the industry we are pleased the Committee did not prescriptive new requirement for financial advisors. Financial advisors and their activities, whether in insurance, mutual fund or securities channels, are already highly regulated. Regulating financial advisors as if they were financia l planners would have had a detrimental impact on the effective distribution of financial products through licensed financial advisors.

Harmonized Standard

We agree that regulation of the financial services sector needs to be more coordinated and it is in the interest of the public and industry to ensure all those who hold themselves out as financial planners meet a defined and rigorous standard of competence, proficiency and ethical practice. We agree that requirements for education, training, credentialing and licensing of persons who hold out as financial planners should be established in a single set of standards.

Steps should be taken to ensure there is no regulatory overlap or duplication of processes, particularly for planners dually licensed under both insurance and securities regulation. We recommend procedures be written that would require communication and information exchanges between all financial sector regulators.

Statutory Best Interest Duty

We believe the current regulatory environment offers substantial protection to consumers. Under Rule No.2 of the Mutual Fund Dealers Association ("MFDA") which req uires that registered advisers and dealers are required to deal fairly, honestly and in good faith in all dealings with their clients. While Investment Industry Regu latory Organization of Canada ("II ROC") has rule 29.1 that requires that dealers and their rep resentatives must observe high standards of ethics and conduct in the transaction of their

business and not engage in any business conduct or practice unbecoming or detrimental to the public interest.

The Canadian Securities Administrators ("CSA" ) is currently consulting on this matter. In its Consultation Paper 33-404 in which the CSA notes that there is no consensus among securities regulators on the value to the consumer of a statutory best interest standard. Without achieving unanimity on a best interest standard by the CSA, the committee should withhold any recommendation on imposing a best interest standard. Also the recently enhanced disclosure rules in the Client Relationship Model should be given the opportunity to demonstrate their effectiveness prior to the consideration of any new regulatory requirements. With the industry currently working on further initiatives with the CSA, the introduction of a best interest standard would add uncertainty and duplication for the industry.

Titles and Holding Out

Regulating the use of titles will be a step forward. Most financial advisors are regulated and licensed for securities, mutual funds and/or insurance and these regulatory bodies oversee the activities of their licensees. II ROC has rules around the use of titles, the MFDA is considering rules, and 33-404 contemplates rules. We expect this matter will be addressed through the existing and proposed regulation. The use of the financial planning title should be subject to similar consideration.

We believe that the Committee should pay particular attention to harmonization in the development and application of financial planning rules with respective regulators, so that consumers can expect uniform levels of competence and service.

Establishing minimum proficiency requirements for those who use financial planning titles would provide the consumer with more confidence that the person they are dealing with is trained and educated to provide the advice that goes along with their title.

Referrals While a referral may be viewed as advice in some general sense, it does not seem reasonable to view it as financial advice. We support restrictions and regulation of referral fees in line with what is found in National Instrument 31-103. The Committee's recommendation will prohibit many forms of referrals that pose no threat to investors

We look forward to being part of a meaningful dialogue between the Committee and industry to ensure that the interests of investors are protected.

Please do not hesitate to contact our office with any questions or comments.


John A. Adams, CPA, CA
Chief Executive Officer