Paola Cifelli
September 11, 2008
Legal & Policy Counsel
Tel: (416) 643-1820
Fax: (416) 867-4015
paola.cifelli@bmo.com
Corporate Secretary
Mutual Fund Dealers Association of Canada
121 King St. West, Suite 1000
Toronto, ON M5H 3T9
Sarah Corrigall-Brown
Senior Legal Counsel
British Columbia Securities Commission
701 West Georgia Street
PO Box 10142, Pacific Centre
Vancouver, BC V7Y 1L2
scorrigall-brown@bcsc.bc.ca
RE:
RESPONSE TO REQUEST FOR COMMENTS – PROPOSED AMENDMENTS TO
MFDA RULE 2.2 AND MFDA POLICY NO. 2
BMO Investments Inc. (“BMOII”) welcomes the opportunity to provide our comments on the MFDA’s
proposed amendments to Rule 2.2 and Policy No. 2. We understand that the intent of the proposed
amendments is to advance certain of the core principles of the Client Relationship Model project, namely
relationship disclosure, performance reporting and ensuring suitability of investments.
BMOII is pleased to express its support for the MFDA's initiatives and the Client Relationship Model
generally; however, we wish to identify and provide context in relation to specific concerns we have
about certain of the proposed amendments.
Rule 2.2 Client Accounts
Rule 2.2.1(a) proposes that the MFDA may prescribe, from time to time, the essential facts relative to
each client that Members would be required to learn. While we agree that there are certain fundamental
facts about all clients that Members must be aware of in order to conduct a proper suitability review and
comply with applicable legislation (such as anti-money laundering), we believe that Members should be
given the flexibility to look to their own core client base to determine what “KYC” information they will
collect rather than having these matters prescribed by the MFDA and being applicable to all Members.
BMOII’s primary business focus is on providing access to quality investment solutions to the Canadian
retail market. For this reason, we focus primarily on collecting, in a