IFB Position Papers

Position Papers

An important part of the work that Independent Financial Brokers does on behalf of its members is in the area of Regulatory Affairs. IFB lobbies the federal and provincial regulators in order to represent the unique viewpoint and business model of the independent broker. Click on the links below to read some of our recent responses to consultation papers, regulatory initiatives, and legislative changes.


IFB responds to FSRA’s draft 2022-2023 priorities – Oct. 2021

IFB responds to New Brunswick’s consultation on regulating the Financial Planner and Financial Advisor titles – Oct. 2021

IFB comments on FSRA’s proposed Guidance on Life Agent Reporting requirements and Insurer Obligations – Oct. 21.

IFB comments on the CSA proposal to create a new, single SRO for the securities industry – Oct. 2021

IFB comments on Saskatchewan proposed title framework for Financial Planners and Financial Advisors – Oct. 2021

IFB comments on FSRA’s Guidance on Proposed Transparent Communication of Enforcement Actions – Sept 2021

IFB comments on FSRA’s second UDAP consultation – Aug 2021

IFB comments on CISRO’s draft Principles of Conduct for Insurance Intermediaries – July 2021

IFB responds to FSRA’s second consultation on the proposed framework to restrict use of the titles Financial Planner and Financial Advisor – June 2021

IFB comments on the CSA consultation on modernizing registration requirements and clarifying outside activities – May 2021

IFB comments on FSRA’s draft rule to amend the Unfair or Deceptive Acts or Practices (UDAP) Regulation – March 2021

IFB provides input to Ontario’s 2021 pre-budget consultation – February 2021

IFB responds to the BC Insurance Council’s consultation on revised guidance for MGAs – February 2021


IFB comments on the Ontario Securities Commission’s draft 2021-22 Statement of Priorities -December 2020

IFB comments on FSRA’s proposed Rule and Guidance on the Financial Planner/Financial Advisor title restriction framework – November 2020

IFB response to FSRA’s draft 2021-2022 Statement of Priorities and Budget – November 2020

IFB comments on FSRA’s Adoption of CCIR Fair Treatment of Guidance – October 2020

IFB submits comments to the Canadian Securities Administrators (CSA) on reforming the SRO Framework – October 2020

IFB responds to Ontario’s request for input to the Fall 2020 budget – October 2020

IFB responds to Ontario’s Capital Markets Modernization Taskforce – September 2020 

IFB comments on the CSA’s proposals to enhance protections for senior and vulnerable clients – July 6, 2020

IFB responds to the OSC proposals to restrict the use of the DSC sales option – June 2020

IFB responds to Ontario pre-budget consultation – February 2020

IFB comments on New Brunswick’s proposed incidental selling of insurance license regime – January 2020


IFB comments on FSRA’s 2020-21 proposed budget and priorities – November 18, 2019

IFB responds to MFDA Discussion Paper on process to accredit third parties for continuing education regime – September 2019

IFB responds to BC on insurance rebating – September 2019

IFB responds to Saskatchewan’s request for input on the regulation of financial planners and financial advisors – September 2019

IFB responds to IIROC proposal to suspend advisors whose dealer has not updated the advisor’s CE file on time – August 2, 2019

IFB responds to the Ontario Securities Commission’s request for comments on its draft Statement of Priorities for 2019-2020 – May 27, 2019

IFB response to FSRA proposed 2019-20 Priorities and Budget – Feb 8, 2019

IFB comments on FSRA draft Fee Rule, January 2019


IFB comments on CSA proposed amendments to National Instrument 81-105 Mutual Fund Practices – Dec 13, 2018

IFB responds to CSA proposals to enhance the Client-Registrant relationship – Oct 19, 2018

IFB comments on proposed MFDA rules – June 20, 2018

IFB comments on BC FIACUIA review – June 19, 2018

IFB response to CCIR CISRO fair treatment of customers – June 18, 2018

IFB comments on OSC 2018-2019 Draft Statement of Priorities – May 28, 2018

IFB response to FSCO FTC guideline – May 2018

IFB response to FSCO Draft 2018 Statement of Priorities – May 18

IFB response to Finance re AML – April 2018

IFB responds to Ontario Ministry of Finance Consultation – April 2018


IFB responds to AMF issues paper on incentives – Oct 2017

IFB responds to BC Insurance Council Fee Increase – Oct 2017

IFB responds to the review of the financial sector framework – Sept 2017

IFB responds to Consultation on Tax Planning Using Private Corporations – Sept 2017

IFB responds to CSA embedded commissions consultation paper – June 2017

IFB submits brief to Federal Finance Standing Committee studying bank sales practices

IFB comments on OSC draft SOP 2017-2018

IFB comments on FSCO draft SOP 2017

IFB response to MFDA CE framework

IFB letter to FCAC

IFB’s letter to the Saskatchewan Minister of Finance – 2017

IFB submission to Ontario Pre-Budget Consultation 2017

IFB responds to MFDA Proposed Amendments to Rule 1.2.5 – Misleading Business Titles Prohibited – Jan 30 2017


IFB response to Deposit Insurance Review Consultation Paper – Nov 30

IFB response to federal Finance review of the financial sector framework. Nov 16

IFB response to CSA Consultation Paper 33-404 – Sept 30 2016

IFB response to CCIR Issues Paper – July 15 2016

IFB submission to Ontario’s Expert Panel on Financial Planning & Financial Advisory Policy Alternatives – Jun 17 2016

IFB comments on data breach consultation – May 31 2016

IFB comments on FSCO draft SOP 2016 – May 31 2016

IFB comments on OSC Priorities – May 9 2016

IFB response to Modernizing the NB Insurance Licensing Framework – Jan 22 2016


IFB comments on revised CMA consultation draft – Dec 21 2015

IFB response to Expert Advisory Panel – Dec 14 2015

IFB comments on MFDA financial planner rule – Dec 4 2015

IFB response to BC Financial Institutions Act – Sep 15 2015

IFB comments on Voluntary Supplement to CPP – Sep 10 2015

IFB comments on Draft Regulations to PCMLTFA – Sep 2 2015

IFB comments to Expert Advisory Panel re FSCO mandate review – Jun 5 2015

IFB comments on ORPP – Feb 13 2015


IFB comments on CCMRS – Dec 8 2014