The Joint Steering Committee on Product Suitability (“JSC”) conducted a public consultation on product suitability in September 2008 which was part of the regulators response to the ABCP crisis. FAIR Canada filed a submission to the JSC and participated in the follow up conference call discussion with other commentators and the JSC.
As a general matter, based on feedback we have had from investors, we need more action from regulators, not more public consultations. Broad consultations in the guise of being able to say that the regulators are doing something diminish regulators credibility. Where consultations are conducted they should be more focused. Further, where the regulators do conduct a public consultation and are genuinely interested in investor input, a 30-day comment period is far too short. We recommend that the standard consultation period be 60 or 90 days (depending on complexity etc.) in the absence of some urgency or need for timely action.
If the JSC is interested in investor feedback, we recommend that the JSC form an investor committee composed of representatives of investors/consumers such as the Consumer Council of Canada, the Small Investor Protection Association, CARP, etc. We would be pleased to participate in such a forum.
