Performance Reporting Amendments Could Increase Burden On Registrants

As we discussed in our post of June 24, the CSA recently published proposed amendments to NI 31-103 Registration Requirements and Exemptions intended to "ensure that clients of all dealers and advisers (registrants)...receive clear and complete disclosure of all charges associated with the products and services they receive, and meaningful reporting on how their accounts perform."

While we discussed the changes in our earlier post, particular attention should be given to the proposals respecting performance reporting. Specifically, the amendments would require that registered firms include original cost information for each security position in a client's account statement. The CSA is also specifically requesting comments on whether the use of tax cost (book value) should be permitted as an alternative.