| Performance
Reporting |
| • |
Recommended
that the focus of the disclosures should be on retail
clients only, |
| • |
Recommended
that cost information be used to provide a summary
account activity report, |
| • |
Recommended
that AIMR standards should be used to calculate
portfolio performance information, |
| • |
Where
multiple AIMR standards are permissible, the SROs
will need to determine whether to prescribe the
use of certain standards to ensure comparable disclosure, |
| • |
It
is expected that the default form of performance
reporting would be account level reporting, but
either account level or portfolio level performance
reporting would be acceptable, |
| • |
If
the dealer makes it available, the retail client
should be allowed to choose between receiving account
level and multiple account level (either individual
portfolio or household portfolio) reporting, |
| • |
If
the dealer makes it available, the retail client
should be allowed to receive performance reporting
with advised/non-advised detail, |
| • |
Recommended
that, in the near term, performance reporting should
only be provided for nominee and client name securities
that are held in custody by the dealer for the client.
While the Working Group agrees that dealers should
be held accountable for the performance of all securities
positions on which they continue to earn revenue,
the significant operational impacts involved make
providing performance information on client named
securities positions that are either held in physical
form by an outside custodian or in book based form
a longer term objective [Dissenting view: OSC
staff do not agree with this limitation, as this
would result in no disclosure by dealers to their
clients in respect of client named securities not
held by the dealer. OSC staff believes that performance
reporting should be provided by the dealer for all
securities for which the dealer continues to receive
compensation. However, OSC staff recognize that
dealers should be able to outsource this function
to take advantage of some of the current sources
of information], |
| • |
It
may also be appropriate to exclude certain securities
where market value is difficult to determine, |
| • |
Recommended
that performance be disclosed for the current year
and since account inception at a minimum, |
| • |
As
practical implementation matter, performance from
rule implementation date could be provided in place
of performance from account inception, |
| • |
The
dealer may make available additional timeframes
that are consistent with the client’s investment
timeframe, |
| • |
Recommended
that performance reporting should be provided on
an annual basis, at a minimum, |
| • |
More
frequent reporting can be provided depending on
the level of service being provided by the dealer
and the client’s willingness to pay for such
service, |
| • |
The
provision of target returns for purposes other than
providing a range of possible returns for risk disclosure
purposes has not been recommended by the Working
Group. |
Performance
Benchmarks |
| • |
Recommended
that an appropriate benchmark should be provided
but if there is no appropriate benchmark, no benchmark
information need be disclosed, |
| • |
Situations
where benchmarks may not be available/appropriate
include: complex portfolios, where no relevant reference
benchmark is available and simple portfolios involving
relatively few securities, where the use of a benchmark
may provide no meaningful information. |
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