Larry: how do you square that with other real professionals who are paid the equivalent of sales commissions: eg doctors, dentists, engineers who only get paid if you contract their services.
The main difference I can see is that even though they are only paid if you show up and contract them, that you expect a proper diagnosis, that is you only are told you need new fillings if in fact your old fillings are no longer good as opposed to a dentist just goldmining in your mouth.
Best wishes.
J
visit breachoftrust.ca for BREACH OF TRUST film info
E-MAIL us at investoradvocate@shaw.ca
Are advisors professionals, or salespeople masquerading?
Re: Are advisors professionals, or salespeople masquerading?
by admin » Sun Nov 22, 2009 11:39 pm
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Sun Nov 22, 2009 11:39 pm
thoughts are
stock salesmen go through a three month correspondence course
doctors go through years of university
stock salesmen do not have a hippocratic oath that says do no harm
doctors do
stock salesmen (and banks) can call themselves advisor without having a CFA or other educational requirements as defined and required in the securities act
doctors cannot call themselves doctor without appropriate board certification
banks who employ stock salesmen, can send 15,000 bank tellers on a mutual fund course and then call this army of sellers "professional advisors" within 30 days
(note the new CIBC posters at the bank that says (talk to one of our 8100 experienced advisors)
Doctors do not play the same game by falsely calling their nurses or receptionists "doctors" in order to allow them to see patients, diagnose patients and thus earn more money for the clinic.
What else?
Doctors get paid by the visit, not by the procedure, or the drug they prescribe.
Stock and fund sellers only get paid IF they do a procedure (whether it is good for the client or not) and/or if they sell a drug.
Stock sellers prescribe the highest compensation product 80% of the time (source IFIC)
Doctors usually do not have this reputation for prescribing the solution that pays them the highest commission or fee.
Stock sellers (especially banks) have learned that they can eliminate independent mutual funds and simply sell everyone the house brand fund, since it makes up to 26 times more money for the firm (source OSC Fair Dealing Model)
Doctors are not known for prescribing "house brand" medicines, that they have manufactured.
I could probably go on at length Jim, but I hope this will suffice to answer your good question. (question was thus: Larry: how do you square that with other real professionals who are paid the equivalent of sales commissions: eg doctors, dentists, engineers who only get paid if you contract their services. )
cheers
larry
stock salesmen go through a three month correspondence course
doctors go through years of university
stock salesmen do not have a hippocratic oath that says do no harm
doctors do
stock salesmen (and banks) can call themselves advisor without having a CFA or other educational requirements as defined and required in the securities act
doctors cannot call themselves doctor without appropriate board certification
banks who employ stock salesmen, can send 15,000 bank tellers on a mutual fund course and then call this army of sellers "professional advisors" within 30 days
(note the new CIBC posters at the bank that says (talk to one of our 8100 experienced advisors)
Doctors do not play the same game by falsely calling their nurses or receptionists "doctors" in order to allow them to see patients, diagnose patients and thus earn more money for the clinic.
What else?
Doctors get paid by the visit, not by the procedure, or the drug they prescribe.
Stock and fund sellers only get paid IF they do a procedure (whether it is good for the client or not) and/or if they sell a drug.
Stock sellers prescribe the highest compensation product 80% of the time (source IFIC)
Doctors usually do not have this reputation for prescribing the solution that pays them the highest commission or fee.
Stock sellers (especially banks) have learned that they can eliminate independent mutual funds and simply sell everyone the house brand fund, since it makes up to 26 times more money for the firm (source OSC Fair Dealing Model)
Doctors are not known for prescribing "house brand" medicines, that they have manufactured.
I could probably go on at length Jim, but I hope this will suffice to answer your good question. (question was thus: Larry: how do you square that with other real professionals who are paid the equivalent of sales commissions: eg doctors, dentists, engineers who only get paid if you contract their services. )
cheers
larry
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Mon Nov 23, 2009 10:31 am
http://www.theglobeandmail.com/globe-in ... le1371646/
Avner Mandelman
Published on Friday, Nov. 20, 2009 5:26PM EST Last updated on Monday, Nov. 23, 2009 3:07AM EST
Most investors assume that Bay Street or Wall Street careers are built on being right, but that's only partly true.
Those who must be right most often are money managers – what's known as the Buy Side. Those on the Sell Side, however, also make a living by knowing how to convince. Luckily, most of them do it by instinct only, not by formal training, or we'd all be in trouble.
The formal art of convincing others is called rhetoric. The Greek and Romans used to teach it, as did the Jesuits, British law schools of old and certain colleges in France. There is a variety of rhetorical styles – Roman, Greek (which includes oratory), British, French, German – but all are meant to do one thing: convince you and push you into action. That brings me to the topic of this column – a warning against letting yourself be convinced without checking things yourself.
Rhetoric is no longer taught formally, so those hit with the real thing for the first time are often helpless before its power. As I noted in another column, when I served as research director at Brown, Baldwin, Nisker I made all five of my analysts take a course in rudimentary rhetoric (written and spoken) in the guise of a presentation course, and within two years they all became ranked No. 1 by the Brendan Woods survey of institutional portfolio managers. Same analysts, same research, same analysis; the only change was rhetorical delivery. Luckily, all five were very good to begin with, or, with their new powers, they could have convinced clients to buy even mediocre picks.
But is rhetoric really such a powerful tool? Let's have a side bar, then, about structured language. Language intended to get results comes in three formats: informative language, fictive language and rhetorical language. The first kind restructures information the way the brain assimilates it most easily – hierarchically. That's how good reports are organized and how effective newspaper and magazine pieces are written.
The second format, fictive language, is meant to raise strong emotions and also has structures of its own. (Fictive techniques can leaven rhetorical delivery to achieve greater power, as Ronald Reagan used to do.)
The third format, rhetorical language, is often the most powerful and is meant to move people to act. That's how Alexander the Great roused his soldiers before battle, how U.S. President Barack Obama energized the Democratic convention, how Sarah Palin captivated the Republican convention and how great entrepreneurs get financing for risky projects. They convince through rhetoric.
The content is relatively unimportant. When a rhetorical format is used correctly, either knowingly or instinctively, it can generate whatever action the speaker (or writer) is calling for: buying a stock, getting financing, pulling a voting lever, or pulling a trigger. Like a great mezzo-soprano who sings sublimely in a language you do not understand, both political rhetoricians and great salespeople can convince and move you by form and structure alone. They can sell, in effect, anything.
Now, though not even close to any of the above masters, Bay Street and Wall Street have their share of practical rhetoricians (or, as they are commonly called, good salespeople) because, by Darwinian elimination, those who cannot convince clients to act, must leave the business. Therefore, I strongly urge you to mistrust your ability to recognize an investment's intrinsic worth if it's delivered by a good salesperson.
Sure, enjoy the rhetoric/salesmanship wherever you find it, but mistrust it too. Because at its best, correct rhetoric is an art; and, as in all art, form is more important than content. The painter Chaim Soutine painted a side of beef, yet created a masterpiece. Picasso painted a broken guitar from six viewpoints at once, and created another. It's not the “what,” but the “how.”
Still disbelieving? Well, take a look. Barack Obama's oral speeches, when transcribed, often say little. As for our own Pierre Elliott Trudeau: I once saw him speak before a sedate audience in Toronto, in classical Cartesian rhetorical style as taught in the École des Sciences Politiques in Paris. The audience swooned. Sure, it was his personality too, but the learned rhetoric was key. Ronald Reagan used an American variety of rhetoric (composed by Peggy Noonan), John F. Kennedy used Ted Sorensen's written speeches and Mr. Obama uses his own (the classical Greek/Roman kind, mixed with oratory). Sarah Palin uses her own style – she's a natural – but surely it's not the language, which she butchers; rather, it's her structures, which are rhetorically correct. As previously noted: It's the how, not the what, where most of the magic resides, both in Washington and on Wall Street and Bay Street.
So, be careful of investing too hastily based on a convincing argument you've just heard from a salesperson or analyst, or recently read in a well-crafted research piece – or, for that matter, in a newspaper column written by some Joe who can string words enticingly. Just because someone convinced you doesn't mean it's right, whether in politics, business or investments. Never rush. Cool down. Wait. Sleuth it out. Don't be too easily convinced. When subjected to correctly structured rhetoric, you are more malleable than you think.
Avner Mandelman
Published on Friday, Nov. 20, 2009 5:26PM EST Last updated on Monday, Nov. 23, 2009 3:07AM EST
Most investors assume that Bay Street or Wall Street careers are built on being right, but that's only partly true.
Those who must be right most often are money managers – what's known as the Buy Side. Those on the Sell Side, however, also make a living by knowing how to convince. Luckily, most of them do it by instinct only, not by formal training, or we'd all be in trouble.
The formal art of convincing others is called rhetoric. The Greek and Romans used to teach it, as did the Jesuits, British law schools of old and certain colleges in France. There is a variety of rhetorical styles – Roman, Greek (which includes oratory), British, French, German – but all are meant to do one thing: convince you and push you into action. That brings me to the topic of this column – a warning against letting yourself be convinced without checking things yourself.
Rhetoric is no longer taught formally, so those hit with the real thing for the first time are often helpless before its power. As I noted in another column, when I served as research director at Brown, Baldwin, Nisker I made all five of my analysts take a course in rudimentary rhetoric (written and spoken) in the guise of a presentation course, and within two years they all became ranked No. 1 by the Brendan Woods survey of institutional portfolio managers. Same analysts, same research, same analysis; the only change was rhetorical delivery. Luckily, all five were very good to begin with, or, with their new powers, they could have convinced clients to buy even mediocre picks.
But is rhetoric really such a powerful tool? Let's have a side bar, then, about structured language. Language intended to get results comes in three formats: informative language, fictive language and rhetorical language. The first kind restructures information the way the brain assimilates it most easily – hierarchically. That's how good reports are organized and how effective newspaper and magazine pieces are written.
The second format, fictive language, is meant to raise strong emotions and also has structures of its own. (Fictive techniques can leaven rhetorical delivery to achieve greater power, as Ronald Reagan used to do.)
The third format, rhetorical language, is often the most powerful and is meant to move people to act. That's how Alexander the Great roused his soldiers before battle, how U.S. President Barack Obama energized the Democratic convention, how Sarah Palin captivated the Republican convention and how great entrepreneurs get financing for risky projects. They convince through rhetoric.
The content is relatively unimportant. When a rhetorical format is used correctly, either knowingly or instinctively, it can generate whatever action the speaker (or writer) is calling for: buying a stock, getting financing, pulling a voting lever, or pulling a trigger. Like a great mezzo-soprano who sings sublimely in a language you do not understand, both political rhetoricians and great salespeople can convince and move you by form and structure alone. They can sell, in effect, anything.
Now, though not even close to any of the above masters, Bay Street and Wall Street have their share of practical rhetoricians (or, as they are commonly called, good salespeople) because, by Darwinian elimination, those who cannot convince clients to act, must leave the business. Therefore, I strongly urge you to mistrust your ability to recognize an investment's intrinsic worth if it's delivered by a good salesperson.
Sure, enjoy the rhetoric/salesmanship wherever you find it, but mistrust it too. Because at its best, correct rhetoric is an art; and, as in all art, form is more important than content. The painter Chaim Soutine painted a side of beef, yet created a masterpiece. Picasso painted a broken guitar from six viewpoints at once, and created another. It's not the “what,” but the “how.”
Still disbelieving? Well, take a look. Barack Obama's oral speeches, when transcribed, often say little. As for our own Pierre Elliott Trudeau: I once saw him speak before a sedate audience in Toronto, in classical Cartesian rhetorical style as taught in the École des Sciences Politiques in Paris. The audience swooned. Sure, it was his personality too, but the learned rhetoric was key. Ronald Reagan used an American variety of rhetoric (composed by Peggy Noonan), John F. Kennedy used Ted Sorensen's written speeches and Mr. Obama uses his own (the classical Greek/Roman kind, mixed with oratory). Sarah Palin uses her own style – she's a natural – but surely it's not the language, which she butchers; rather, it's her structures, which are rhetorically correct. As previously noted: It's the how, not the what, where most of the magic resides, both in Washington and on Wall Street and Bay Street.
So, be careful of investing too hastily based on a convincing argument you've just heard from a salesperson or analyst, or recently read in a well-crafted research piece – or, for that matter, in a newspaper column written by some Joe who can string words enticingly. Just because someone convinced you doesn't mean it's right, whether in politics, business or investments. Never rush. Cool down. Wait. Sleuth it out. Don't be too easily convinced. When subjected to correctly structured rhetoric, you are more malleable than you think.
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Tue Dec 01, 2009 3:05 pm
- images.jpeg (8.94 KiB) Viewed 758 times
RULES? WE DONT NEED NO STINKING RULES!
copy of an e-mail sent to various OSC staff, FAIR staff, etc
Re: How do you justify using “adviser or advisor” when the CSA members licensed market registrants as
“salespersons” prior to 07-17-09 and as CSA arbitrarily changed to “dealer representatives” beginning on 07-17-09?[quote][/quote]
As per my voice mails today, former SEC Chairman (1991—2001), Arthur Levitt, called me last Wednesday, November 25th.
I am preparing a fact based paper for Arthur on our Canadian securities acts for the use of the word “adviser or advisor” by our Canadian market registrants in their titles: Financial Adviser, Investment Advisor, etc.
Would you please provide me with answers to my following questions and any additional relevant information that I may forward to Arthur Levitt:
Q. Where does the phrase – “Financial or Investment Adviser / Advisor” title originate that is used numerous times on both the OSC’s own web site and the InvestorEd.ca web site?
FACTS: The word “Adviser or Advisor” is not an OSC / CSA / SFSC / BCSC licensed word for market registrants.
Your CSA market registrant licensed words are: “salesperson” and / or “dealer representative”
Arthur spent a significant amount of time asking me about my thoughts on “fiduciary” v. “salesperson” licensing and telling me how my 1994 point-of-sale thesis played an influencing role in their “predation” Bill that the Obama Administration sent to Congress on July 10, 2009 – their Bill to kill a “predation” practices culture in their securities industry and move toward implementing a “fiduciary” culture amongst broker dealers that will parallel a physicians “Hippocratic Oath”.
Best regards,
Joe Killoran
(advocate comments......there would appear to be rules by all regulatory and self regulatory agencies against title inflation or misrepresentation of ones license category, and yet it would appear that all of these rules are overlooked in favor of marketing. Does this systemic industry and regulatory willingness to ignore its own rules point clearly to the "salesperson or advisor" question posed in this topic? Why will no regulator in Canada speak to this misrepresentation of the public? Hiding regulatory failures perhaps?)
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Wed Dec 16, 2009 12:59 pm
CHUCK JAFFE
Dec. 16, 2009, 12:01 a.m. EST · Recommend (2) · Post:
Missed a few spots
Commentary: 'Sweeping' financial reforms don't clean house
View all Chuck Jaffe ›
‹ Previous Column
Naughty funds get lumps of coal
First Take ›
Intel's legal woes appear to be far from over
Alert Email Print Share
By Chuck Jaffe, MarketWatch
BOSTON (MarketWatch) -- When it comes to protecting consumers from rogue financial advisers, politicians just can't get out of their own way. The result is sound and fury, accomplishing nothing.
As part of the sweeping financial services reforms that passed in the House this week, there was a requirement for the Securities & Exchange Commission to write rules that would establish a "fiduciary duty" for brokers who provide investment advice. While most people were focused on the broader aspects of regulatory reform, this was the one element most likely to hit home for financial consumers.
Some fund firms deserve a lump of coal
What happens when mutual-fund companies don't look out for investors? They get a lump of coal from MarketWatch's Chuck Jaffe.
At issue is one of the dirty little secrets in the financial advice world, namely that some people you trust for advice may not have your best interests at heart. Brokers -- in fact any type of intermediary whose primary job is selling products -- live by the standard of "suitability," meaning that the investments they select and sell to clients must be suitable for the buyer. Whatever they pitch, they must believe that the investment is appropriate for the investor and the situation.
By comparison, investment advisers who make money giving advice rather than selling products must live by a "fiduciary standard," meaning they have a responsibility to put your best interests ahead of their own. If it's not in your best interests -- even if it's suitable and appropriate -- they shouldn't sell it.
Broke and broker
Where things have gotten confusing over the years is that there are plenty of people who technically are brokers, working for one of the name-brand brokerage houses, but who function as financial planners or advisers. They may act like they are selling advice, but the work under the legal standard of suitability; brokerage firms felt it was in their best interests to create a class of counselor who could compete with full-service advisory community, they just didn't think it was in their best interests to put the customer's interests first.
The debate has been raging for years, and seemingly every legislator and regulator who has looked at it has said that the time has come for one fiduciary standard. It was written into the House bill, it's part of the Senate version and most industry watchers feel this is an inevitable, and positive, step.
And it might have been just that, had it not been for one little qualifier that was stuck into the Wall Street Reform and Consumer Protection Act of 2009: "Nothing in this section shall require a broker or dealer or registered representative to have a continuing duty of care or loyalty to the customer after providing personalized investment advice about securities."
Confused? You should be.
This means that while you work with a broker-planner who is giving you advice, the fiduciary standard applies; the moment they act like a broker, suitability is all that matters.
At the time they give you the advice, therefore, it must be in your best interest. At the time they sell you the securities, however, they no longer have to be acting in your best interest, they need only be selling something suitable.
Messing with success
This is a provision only a defense lawyer could love, and it renders the fiduciary provision of these bills useless.
In the financial planning world, this practice of changing standards actually happens all the time. It's known as "hat switching," where an adviser does a variety of jobs for the customer but has the ability to avoid the highest legal standards of consumer protection whenever it is most expedient.
The little change was something that lobbyists pushed for, because it could cover discount brokerages, where consumers typically turn to have their trades executed -- pursuing their own ideas rather than following an adviser's -- but where they may want some advice or ask for a second opinion along the way. Poppycock.
Sell securities and identify yourself as being a salesman of investment products, and you're a broker. Don't give advice, don't try to do more than process trades and you can live under the suitability standard. Give advice, and you need to be able to show that the customer's best interests were properly served.
It should be that simple, so straightforward, that even an elected official can't muck it up.
These may sound like fine-line distinctions and small stuff, but it isn't just lip service. A fiduciary standard requires more disclosure concerning possible conflicts of interest, and raises the liability stakes for someone providing investment advice; that means greater consumer protection, precisely what the government has been promising as it has pushed for this reform process.
We've already seen headlines saying that the House has passed "sweeping regulatory reforms," and we'll soon see the same kind of platitudes from the Senate. Sadly, it may all just be platitudes. The top lines of this reform are meant to make you feel safer and better protected. In reality, these "changes" aren't likely to change much of anything.
Chuck Jaffe is a senior MarketWatch columnist. His work appears in many U.S. newspapers.
Dec. 16, 2009, 12:01 a.m. EST · Recommend (2) · Post:
Missed a few spots
Commentary: 'Sweeping' financial reforms don't clean house
View all Chuck Jaffe ›
‹ Previous Column
Naughty funds get lumps of coal
First Take ›
Intel's legal woes appear to be far from over
Alert Email Print Share
By Chuck Jaffe, MarketWatch
BOSTON (MarketWatch) -- When it comes to protecting consumers from rogue financial advisers, politicians just can't get out of their own way. The result is sound and fury, accomplishing nothing.
As part of the sweeping financial services reforms that passed in the House this week, there was a requirement for the Securities & Exchange Commission to write rules that would establish a "fiduciary duty" for brokers who provide investment advice. While most people were focused on the broader aspects of regulatory reform, this was the one element most likely to hit home for financial consumers.
Some fund firms deserve a lump of coal
What happens when mutual-fund companies don't look out for investors? They get a lump of coal from MarketWatch's Chuck Jaffe.
At issue is one of the dirty little secrets in the financial advice world, namely that some people you trust for advice may not have your best interests at heart. Brokers -- in fact any type of intermediary whose primary job is selling products -- live by the standard of "suitability," meaning that the investments they select and sell to clients must be suitable for the buyer. Whatever they pitch, they must believe that the investment is appropriate for the investor and the situation.
By comparison, investment advisers who make money giving advice rather than selling products must live by a "fiduciary standard," meaning they have a responsibility to put your best interests ahead of their own. If it's not in your best interests -- even if it's suitable and appropriate -- they shouldn't sell it.
Broke and broker
Where things have gotten confusing over the years is that there are plenty of people who technically are brokers, working for one of the name-brand brokerage houses, but who function as financial planners or advisers. They may act like they are selling advice, but the work under the legal standard of suitability; brokerage firms felt it was in their best interests to create a class of counselor who could compete with full-service advisory community, they just didn't think it was in their best interests to put the customer's interests first.
The debate has been raging for years, and seemingly every legislator and regulator who has looked at it has said that the time has come for one fiduciary standard. It was written into the House bill, it's part of the Senate version and most industry watchers feel this is an inevitable, and positive, step.
And it might have been just that, had it not been for one little qualifier that was stuck into the Wall Street Reform and Consumer Protection Act of 2009: "Nothing in this section shall require a broker or dealer or registered representative to have a continuing duty of care or loyalty to the customer after providing personalized investment advice about securities."
Confused? You should be.
This means that while you work with a broker-planner who is giving you advice, the fiduciary standard applies; the moment they act like a broker, suitability is all that matters.
At the time they give you the advice, therefore, it must be in your best interest. At the time they sell you the securities, however, they no longer have to be acting in your best interest, they need only be selling something suitable.
Messing with success
This is a provision only a defense lawyer could love, and it renders the fiduciary provision of these bills useless.
In the financial planning world, this practice of changing standards actually happens all the time. It's known as "hat switching," where an adviser does a variety of jobs for the customer but has the ability to avoid the highest legal standards of consumer protection whenever it is most expedient.
The little change was something that lobbyists pushed for, because it could cover discount brokerages, where consumers typically turn to have their trades executed -- pursuing their own ideas rather than following an adviser's -- but where they may want some advice or ask for a second opinion along the way. Poppycock.
Sell securities and identify yourself as being a salesman of investment products, and you're a broker. Don't give advice, don't try to do more than process trades and you can live under the suitability standard. Give advice, and you need to be able to show that the customer's best interests were properly served.
It should be that simple, so straightforward, that even an elected official can't muck it up.
These may sound like fine-line distinctions and small stuff, but it isn't just lip service. A fiduciary standard requires more disclosure concerning possible conflicts of interest, and raises the liability stakes for someone providing investment advice; that means greater consumer protection, precisely what the government has been promising as it has pushed for this reform process.
We've already seen headlines saying that the House has passed "sweeping regulatory reforms," and we'll soon see the same kind of platitudes from the Senate. Sadly, it may all just be platitudes. The top lines of this reform are meant to make you feel safer and better protected. In reality, these "changes" aren't likely to change much of anything.
Chuck Jaffe is a senior MarketWatch columnist. His work appears in many U.S. newspapers.
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Sun Jan 03, 2010 3:27 pm
FORBES
http://www.forbes.com/2009/12/22/financ ... hange.html
Financial Regulation
Hey Adviser: Who's Your Daddy?
John E. Girouard 12.22.09, 4:30 PM ET
The 2008 meltdown and the recession have upended the financial services industry, leaving a lot of clients feeling so burned that a growing number are taking the perilous step of going it alone. Although there is plenty of blame to go around, the core problem has been the system by which most investment professionals are trained and paid--by the companies whose products they sell.
This built-in conflict of interest is emerging as a major issue that the financial services industry needs to address before regulators get to it first. That's what's happened in the U.K. where authorities are tearing up the old playbook, enacting new rules that in 2012 will effectively end the commission system of compensation. Whether or not such a radical change is in store here, it's time to rethink how, and by whom, advisers are paid.
Conscientious professionals who understand the value of long-term relationships should be asking themselves a basic question: Who do I work for, the company that writes my commission check, or the client whose outcome I'm supposed to be planning?
We know what the answer has been: Most financial professionals, from brokers at Wall Street giants on down to the individual practitioner, have been trained to think like sales people. They get most of their knowledge about the investment vehicles they offer clients from the companies that invented and market them.
What they learn and the materials they distribute are tailored to make it easy and simple to close a sale. Few advisers have time to stop and read the fine print to figure out if a particular investment is likely to perform as presented in the brochure, and whether it makes sense for a particular client. Instead of true financial planning, this is marketing intended to move merchandise so everyone can make their quarterly numbers.
The challenge facing the growing crowd of independent advisers who want to change the system is how to keep their businesses afloat while making the transition from sales person to educated and objective financial partner. Having made that transition during the past several decades as a financial planner, I know how big a challenge it can be.
The paradox is that among the most wealthy and sophisticated investors, paying for the advice of wealth managers, tax planners and estate attorneys has long been the norm. But most advisers catering to the vast majority of the investing public have to be jacks-of-all-trades, which by definition makes them masters of none. On any given day, a full-service financial planner may wear an investment advisory hat, a product salesman hat or a commission-oriented insurance hat. The system is designed to encourage selling products that generate commissions, at the expense of truly objective, client-specific advice.
Although people expect to pay lawyers, accountants and doctors for expertise, and everyone knows there is a minimum charge to have a plumber come to your home just to look at your backed-up toilet, most investors think of product commissions as coming out of someone else's pocket. They resist the notion that it would be better for them to pay for an adviser's time and expertise.
This is a perception gap that haunts many client-adviser relationships, and in the U.K. it is manifesting itself in a profound change that is causing consternation among investment professionals there. That nation's Financial Services Authority, the principal regulatory agency governing investment advice and the sale of investment products, has adopted new rules that by 2012 will replace the commission-driven system with upfront fees paid by clients or deducted from their investments.
The other big challenge is that there are many people who call themselves financial planners but relatively few who have experience and knowledge across the spectrum of financial vehicles. There are an estimated 600,000 stock and bond brokers in the U.S., but only about 50,000 certified financial planners, according to the Certified Financial Planner Board of Standards.
The financial services industry makes its living designing and promoting solutions to problems that can be neatly packaged, easily described, quickly sold, and will become obsolete so that clients will be compelled to "trade up" to the new and improved version. In this universe, an insurance-oriented professional or broker only knows how to solve problems with insurance. A broker who knows everything about mutual funds is lost when it comes to insurance, and has no incentive to sell it, even though it might be in the client's best interests.
The events of the past two years have left the financial services industry discredited to a degree we haven't seen since the deep recessions of the 1970s when an entire generation of clients abandoned Wall Street in disgust. Wall Street responded by discounting commissions, pushing into new areas of business, and promoting trading and speculation. The bull market that followed established a new way of doing business that benefited from short-term fads and "silver-bullet" product cycles: tax shelters, 401(k) plans, 529 college funds, target-date funds, Monte Carlo simulations, and so on.
The solution for our industry and for advisers who are in it for the long haul and the right reasons is to create a broader and more vigorous educational structure to teach advisers how to be true financial planners. It shouldn't be enough for an adviser to succeed just by rattling off company sales pitches and collecting signatures on lengthy disclosure forms.
Real financial planning takes into account every available financial vehicle, a client's health, family situation, business interests and so on. Although our industry has a number of certification programs, none offer the kind of education I wish I'd had access to when I got started three decades ago.
Companies that create and market investment products would do well to invest in teaching advisers and planners exactly how their products work, during bad times as well as good, recognizing that true transparency and education are good for business by reducing the risks associated with failure. If clients understand exactly how everything they've bought works, their financial plans are more likely to succeed, resulting in fewer complaints and litigation, as well as increased loyalty and referrals.
One reads a lot these days about flawed human behaviors around money and widespread financial illiteracy. This is a real issue, but before we blame the clients, we need to raise financial literacy among investment professionals, and eliminate conflicts of interest.
John E. Girouard is a financial writer based in Washington, D.C., and author of "The Ten Truths of Wealth Creation."
http://www.forbes.com/2009/12/22/financ ... hange.html
Financial Regulation
Hey Adviser: Who's Your Daddy?
John E. Girouard 12.22.09, 4:30 PM ET
The 2008 meltdown and the recession have upended the financial services industry, leaving a lot of clients feeling so burned that a growing number are taking the perilous step of going it alone. Although there is plenty of blame to go around, the core problem has been the system by which most investment professionals are trained and paid--by the companies whose products they sell.
This built-in conflict of interest is emerging as a major issue that the financial services industry needs to address before regulators get to it first. That's what's happened in the U.K. where authorities are tearing up the old playbook, enacting new rules that in 2012 will effectively end the commission system of compensation. Whether or not such a radical change is in store here, it's time to rethink how, and by whom, advisers are paid.
Conscientious professionals who understand the value of long-term relationships should be asking themselves a basic question: Who do I work for, the company that writes my commission check, or the client whose outcome I'm supposed to be planning?
We know what the answer has been: Most financial professionals, from brokers at Wall Street giants on down to the individual practitioner, have been trained to think like sales people. They get most of their knowledge about the investment vehicles they offer clients from the companies that invented and market them.
What they learn and the materials they distribute are tailored to make it easy and simple to close a sale. Few advisers have time to stop and read the fine print to figure out if a particular investment is likely to perform as presented in the brochure, and whether it makes sense for a particular client. Instead of true financial planning, this is marketing intended to move merchandise so everyone can make their quarterly numbers.
The challenge facing the growing crowd of independent advisers who want to change the system is how to keep their businesses afloat while making the transition from sales person to educated and objective financial partner. Having made that transition during the past several decades as a financial planner, I know how big a challenge it can be.
The paradox is that among the most wealthy and sophisticated investors, paying for the advice of wealth managers, tax planners and estate attorneys has long been the norm. But most advisers catering to the vast majority of the investing public have to be jacks-of-all-trades, which by definition makes them masters of none. On any given day, a full-service financial planner may wear an investment advisory hat, a product salesman hat or a commission-oriented insurance hat. The system is designed to encourage selling products that generate commissions, at the expense of truly objective, client-specific advice.
Although people expect to pay lawyers, accountants and doctors for expertise, and everyone knows there is a minimum charge to have a plumber come to your home just to look at your backed-up toilet, most investors think of product commissions as coming out of someone else's pocket. They resist the notion that it would be better for them to pay for an adviser's time and expertise.
This is a perception gap that haunts many client-adviser relationships, and in the U.K. it is manifesting itself in a profound change that is causing consternation among investment professionals there. That nation's Financial Services Authority, the principal regulatory agency governing investment advice and the sale of investment products, has adopted new rules that by 2012 will replace the commission-driven system with upfront fees paid by clients or deducted from their investments.
The other big challenge is that there are many people who call themselves financial planners but relatively few who have experience and knowledge across the spectrum of financial vehicles. There are an estimated 600,000 stock and bond brokers in the U.S., but only about 50,000 certified financial planners, according to the Certified Financial Planner Board of Standards.
The financial services industry makes its living designing and promoting solutions to problems that can be neatly packaged, easily described, quickly sold, and will become obsolete so that clients will be compelled to "trade up" to the new and improved version. In this universe, an insurance-oriented professional or broker only knows how to solve problems with insurance. A broker who knows everything about mutual funds is lost when it comes to insurance, and has no incentive to sell it, even though it might be in the client's best interests.
The events of the past two years have left the financial services industry discredited to a degree we haven't seen since the deep recessions of the 1970s when an entire generation of clients abandoned Wall Street in disgust. Wall Street responded by discounting commissions, pushing into new areas of business, and promoting trading and speculation. The bull market that followed established a new way of doing business that benefited from short-term fads and "silver-bullet" product cycles: tax shelters, 401(k) plans, 529 college funds, target-date funds, Monte Carlo simulations, and so on.
The solution for our industry and for advisers who are in it for the long haul and the right reasons is to create a broader and more vigorous educational structure to teach advisers how to be true financial planners. It shouldn't be enough for an adviser to succeed just by rattling off company sales pitches and collecting signatures on lengthy disclosure forms.
Real financial planning takes into account every available financial vehicle, a client's health, family situation, business interests and so on. Although our industry has a number of certification programs, none offer the kind of education I wish I'd had access to when I got started three decades ago.
Companies that create and market investment products would do well to invest in teaching advisers and planners exactly how their products work, during bad times as well as good, recognizing that true transparency and education are good for business by reducing the risks associated with failure. If clients understand exactly how everything they've bought works, their financial plans are more likely to succeed, resulting in fewer complaints and litigation, as well as increased loyalty and referrals.
One reads a lot these days about flawed human behaviors around money and widespread financial illiteracy. This is a real issue, but before we blame the clients, we need to raise financial literacy among investment professionals, and eliminate conflicts of interest.
John E. Girouard is a financial writer based in Washington, D.C., and author of "The Ten Truths of Wealth Creation."
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Sun Jan 03, 2010 3:34 pm
Forbes.com (some evidence that every "advisor" is actually a salesman dressed in trustworthy clothing.....advocate)
http://www.forbes.com/2009/12/22/financ ... hange.html
Practice Management
Earn Trust, Build The Business
Richard Weylman, 12.08.09, 04:10 PM EST
Relationships based on respect and trust are what make a high-end practice successful.
It's a question on many advisers' minds: What are high-net-worth investors looking for in an adviser today?
In the current post-crisis climate, the dynamics for connecting with new clients have changed dramatically. Everyone, particularly the affluent and wealthy, are far more value-conscious.
If anything has become readily apparent, it is that advisers looking to grow their high-end practices must adopt a new approach to marketing based more on building sustainable relationships than notching the next transaction.
If you are interested in growing your business, you'll have to come up with answers to some key questions:
What am I doing to earn trust in my markets?
Affluent and wealthy investors will only conduct business with advisers they can trust. This is especially true now given the various scandals and schemes in the news. Whether they learn about you through referrals from a close friend, or because you are providing pro-bono services to a local charity, high-net-worth clients want third-party proof of credibility.
This means you have to actively work to establish a positive and trusted reputation.Most of us tend to buy "people" before we buy products. We are looking to work with someone who truly understands our goals, aspirations and complexities. In practice, what does this mean?
First, demonstrate a passion for your clients and prospective clients, and get to know them first as individuals. Second, get involved and become visible in their network. Third, be authentically interested and engaged in their goals, dreams, lifestyle and business activities. Ask questions, remember their answers and follow-up with related articles, people or ideas they should know about.
Am I selling products, or connecting with people?
Focusing on people requires more than targeting individuals who have money in motion or those who have substantial assets. Truly effective advisers identify how their best clients and prospects network and communicate, and then they use those avenues to raise their own profile. For instance, serving on a committee within the association that supports their industry, or getting involved in the fundraising activities of a local charity where their best prospects are active.
In other words, make the "people side" of the business your service model. Clients and prospective clients feel much more secure when they know, deep down, that their adviser isn't trying to push products on them, but is actually a knowledgeable partner who wants to help them work through their financial issues with them in an open and honest way. In addition, advisers must be able to clearly articulate the distinct value they bring to the high net worth, sophisticated investor.
As an example, just creating financial plans is not distinct, but organizing all of a client's assets in a tax efficient way is a differentiator. The goal is to define what you do for clients and prompt them to ask the question, "How do you do that?"
Am I building valuable relationships, or just making sales?
Unfortunately, few advisers understand the difference between selling and marketing. They are wedded to the belief that success lies in "making a sale." The irony is that usually, a prospective client wouldn't even meet or speak with an adviser if they weren't already signed on to the adviser's product, or sales, offering. If you're looking to buy a house, do you want your realtor telling you how important it is to make a bid as soon as possible and how good they are at closing deals, or do you want them to listen to your thoughts, questions and concerns?
High-net-worth investors are most interested in an adviser's willingness to hear out their ideas and needs. Being a good listener is simple. Let them speak, absorb what they say. Then take a step back and ask, "What are three things you would like to achieve (today, this year, with your life)?" This gives clients an opportunity to discuss the things that are most important to them. It demonstrates that you want to understand them on a deeper level and prioritize the things that are top of mind for them.
Building valuable client relationships is the only way to establish a sustainable high-end practice in the post-crisis world. The insights gained in this process will not only help with bringing in new clients, it will make you a better adviser to the clients you have. You'll be more attuned to their particular needs and better able to tailor your entire platform of specialized services. You'll be the adviser they recommend.
Richard Weylman is founder of Richard Weylman Inc., a marketing consultancy helping financial businesses market to the affluent and wealthy through coaching and educational services, including the Weylman Center for Excellence in Practice Management.
http://www.forbes.com/2009/12/22/financ ... hange.html
Practice Management
Earn Trust, Build The Business
Richard Weylman, 12.08.09, 04:10 PM EST
Relationships based on respect and trust are what make a high-end practice successful.
It's a question on many advisers' minds: What are high-net-worth investors looking for in an adviser today?
In the current post-crisis climate, the dynamics for connecting with new clients have changed dramatically. Everyone, particularly the affluent and wealthy, are far more value-conscious.
If anything has become readily apparent, it is that advisers looking to grow their high-end practices must adopt a new approach to marketing based more on building sustainable relationships than notching the next transaction.
If you are interested in growing your business, you'll have to come up with answers to some key questions:
What am I doing to earn trust in my markets?
Affluent and wealthy investors will only conduct business with advisers they can trust. This is especially true now given the various scandals and schemes in the news. Whether they learn about you through referrals from a close friend, or because you are providing pro-bono services to a local charity, high-net-worth clients want third-party proof of credibility.
This means you have to actively work to establish a positive and trusted reputation.Most of us tend to buy "people" before we buy products. We are looking to work with someone who truly understands our goals, aspirations and complexities. In practice, what does this mean?
First, demonstrate a passion for your clients and prospective clients, and get to know them first as individuals. Second, get involved and become visible in their network. Third, be authentically interested and engaged in their goals, dreams, lifestyle and business activities. Ask questions, remember their answers and follow-up with related articles, people or ideas they should know about.
Am I selling products, or connecting with people?
Focusing on people requires more than targeting individuals who have money in motion or those who have substantial assets. Truly effective advisers identify how their best clients and prospects network and communicate, and then they use those avenues to raise their own profile. For instance, serving on a committee within the association that supports their industry, or getting involved in the fundraising activities of a local charity where their best prospects are active.
In other words, make the "people side" of the business your service model. Clients and prospective clients feel much more secure when they know, deep down, that their adviser isn't trying to push products on them, but is actually a knowledgeable partner who wants to help them work through their financial issues with them in an open and honest way. In addition, advisers must be able to clearly articulate the distinct value they bring to the high net worth, sophisticated investor.
As an example, just creating financial plans is not distinct, but organizing all of a client's assets in a tax efficient way is a differentiator. The goal is to define what you do for clients and prompt them to ask the question, "How do you do that?"
Am I building valuable relationships, or just making sales?
Unfortunately, few advisers understand the difference between selling and marketing. They are wedded to the belief that success lies in "making a sale." The irony is that usually, a prospective client wouldn't even meet or speak with an adviser if they weren't already signed on to the adviser's product, or sales, offering. If you're looking to buy a house, do you want your realtor telling you how important it is to make a bid as soon as possible and how good they are at closing deals, or do you want them to listen to your thoughts, questions and concerns?
High-net-worth investors are most interested in an adviser's willingness to hear out their ideas and needs. Being a good listener is simple. Let them speak, absorb what they say. Then take a step back and ask, "What are three things you would like to achieve (today, this year, with your life)?" This gives clients an opportunity to discuss the things that are most important to them. It demonstrates that you want to understand them on a deeper level and prioritize the things that are top of mind for them.
Building valuable client relationships is the only way to establish a sustainable high-end practice in the post-crisis world. The insights gained in this process will not only help with bringing in new clients, it will make you a better adviser to the clients you have. You'll be more attuned to their particular needs and better able to tailor your entire platform of specialized services. You'll be the adviser they recommend.
Richard Weylman is founder of Richard Weylman Inc., a marketing consultancy helping financial businesses market to the affluent and wealthy through coaching and educational services, including the Weylman Center for Excellence in Practice Management.
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Mon Jan 04, 2010 10:57 am
Hi Larry,
I wanted to say thank you for your dedication to improve investment practices in Canada. My husband worked briefly as an investment planner but HATED the fact that it was about selling and not about teaching people how to manage their money. Additionally, my father filed a lawsuit (and won) against RBC's mortgage insurance division after they failed to follow through on their policy. As a writer I would like to help out as I can (I'm a full time salesperson but also a writer) so if you have a press release mailing list, please add me to it.
Thank you and God bless.
I wanted to say thank you for your dedication to improve investment practices in Canada. My husband worked briefly as an investment planner but HATED the fact that it was about selling and not about teaching people how to manage their money. Additionally, my father filed a lawsuit (and won) against RBC's mortgage insurance division after they failed to follow through on their policy. As a writer I would like to help out as I can (I'm a full time salesperson but also a writer) so if you have a press release mailing list, please add me to it.
Thank you and God bless.
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Fri Jan 08, 2010 9:58 pm
- images.jpeg (2.97 KiB) Viewed 634 times
1. You might miss out on being misrepresented by someone with a three month correspondence course, paid by commissions, telling you to "trust me" with your life's work.
2. You might miss out on being sold the highest cost mutual fund class available to be sold to you, complete with the greatest hidden penalties.
3. You might miss out on being sold the "house brand" mutual fund, where the house earns up to 26 times more profit by putting you in their own product.
4. You will probably never enjoy the benefits of losing money in Asset Backed Commercial Paper, bad income trusts, or other dubious investment offerings that occasionally get pushed down onto customers when an investment firm finds itself stuck with a bad product.
5. Portus, Crocus, Eatons, Global Crossing, Spinright, all kinds of essentially "doomed from start" investments will not be pushed upon you.
6. You will miss out on all the phone calls suggesting that you change your investments immediately, and you will never ever know whether such change in strategy were for the commission benefit of the salesperson, or for your own benefit.
7. You will miss out on the joy of having a complaint with a large financial institution, in which the answer to any and all customer complaints goes something like this, "we are very sorry for your loss, but you were the author of your own misfortune", "you at all times were aware of every transaction and we take no responsibility".
7.5 You will then miss out on the joy of appealing (for years) your financial abuse to numerous so called "self regulatory" bodies, only to discover five years down the road that you have been appealing to persons who are paid a salary by the very investment industry that you are complaining of.
8. You will miss out on the joy of paying (in addition to the sales commissions and trailer commissions in #2 above) the world's highest mutual fund fees.
9. You will miss being invited to sales presentations where a free lunch is provided and a sales pitch is given.
10. You will miss exciting presentations on topics such as "estate planning", etc., where the true motive is selling you life insurance.
11. You will miss out on having a person gain your attention with various methods to convey trust, respectability and credibility to you, and then perhaps misuse or abuse this trust for financial gain.
12. You will miss out on getting purchase confirmations and monthly statements written by an accountant, which do not clarify, and do not help you to fully understand what it is that you own and why you own it.
13. Even if you found the most trustworthy investment salesperson, and the one most interested in your financial well being (they are out there) you will miss out on the predatory nature of the firm they represent, which strange as it may seem, often brings little ethics, morality or integrity to the process, after all they are a corporation, not a human. This systemic design will help to weed out and eliminate the most ethical salespeople, and promote the less ethical into management.
14. You might even miss the joy of paying full commissions for every purchase, and THEN having your trusted "advisor" sell you on the idea of a "fee based" account where you will "never have to pay a commission again". Yipee!! You will go from paying nothing to hold your investments, to paying an additional 1% or 2% annually for holding these very same investments, and he will have gotten another annual income from you on top of the commission income earned already. It is called double dipping, and the best in the business that I saw often received promotion for their "revenue generating" abilities.
15. You will miss the joy of discovering that the industry (investment sales) in Canada is entirely self regulatory, and so incestuous that as of Jan 8th 2010, I can honestly say that there is not one national government organization at a federal, provincial or any level that has as its sole mandate that of investor protection. Not one in a country of 30 million people. Further than each and every single organization who claim or purport to protect investors in Canada can be found to be funded 100% by dollars coming from the very investment industry they regulate.
16. What 15 above is saying, is that you will miss out playing in a game where the referees are bought and paid for by the other team.
17. You will miss out on the tremendous joy, after 35 years of investing with your trusted "advisor" of learning that on average it has cost you as much as 2% in drag on your investment performance to carry this person on your back all these years. A number like 2%, when compounded over a lengthy period like 35 years will result in you having approximately HALF as much money as you should, would or could have had were it not for the burden of the "advice". They will of course have the other half.
18. You will miss out on dealing with a person who cannot produce even a written license certificate from provincial or federal governments. Who will have no university degree to claim related to their field of work, and who can become licensed (but not show a license) in less time than it takes to become a plumber or a hairdresser in Alberta. "Trust me"
19. You will never know the joy of being told that your trusted "advisor" has been given the phony and misleading title of "vice president", which is intended to lure you into thinking that you have an excellent representative, a high ranking and important member of the company. Read the case of Markarian Vs CIBC at www.investorvoice.ca if you want to see what a Quebec Superior court judge says about such phony marketing attempts.
to be continued............at www.investoradvocates.ca
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Wed Jan 20, 2010 3:18 pm
From: larry elford <lelford@shaw.ca>
To: record@osc.gov.on.ca
Date: 01/17/2010 05:13 PM
Subject: please forward this question to EREZ BLUMBERGER at the OSC
"Erez Blumberger, manager of registrant regulation: Firms or individuals trading or advising must be registered with us."
Erez, from an article recently by Ellen Roseman, I found your name and function.
For similar research and journalistic purposes I too, am trying to determine what registration category is necessary to sell or advise the public on investments. Also I recall a license category titled "advisor" and was wondering if that category still exists and what the qualifications and requirements are to use it?
Would it be possible for you to comment on the two questions above, and comment also on the question of title inflation or advisor representation posed below?
I am trying to answer a question of what an investment person can or cannot represent him or herself as.
Are there any guidelines or rules about what can be represented and what cannot?
thanks much for any help you can be.
Larry Elford
On 19-Jan-10, at 2:36 PM, inquiries@osc.gov.on.ca wrote:
Dear Mr. Elford,
Thank you for your inquiry directed to Erez Blumberger, Manager Registrant Regulation, of the Ontario Securities Commission (OSC). Mr. Blumberger has asked that I review your matter, and respond on his behalf.
1. What registration category is necessary to sell or advise the public on investments?
The appropriate category in which a firm or individual should be registered is entirely dependent on the kinds of services they provide and the products they offer.
In general, a firm must register if they are in the business of trading or advising on securities or if they act as an underwriter or manage an investment fund.
Individuals must register if they trade, underwrite or advise on behalf of a registered dealer or adviser, or act as the ultimate designated person (UDP) or chief compliance officer (CCO) of a registered firm. Individuals who act on behalf of an investment fund manager do not have to register. However, an investment fund’s UDP and CCO must register.
It should be noted that the definition of trade in subsection 1(1) of the Ontario Securities Act (Act) includes activities made in furtherance of a trade, such as any act, advertisement, solicitation, conduct, or negotiation. Other relevant terms, such as “adviser” and “investment fund” are also defined in this subsection. The basic requirement for registration is in section 25 of the Act. Categories of registration are provided in sections 25 and 26 of the Act (for dealer and adviser categories) and in section 7.3 of NI 31-103 (for the investment fund manager category).
Individuals must be sponsored by a firm currently registered in the applicable category with the OSC. It is possible to register your own company as a registrant, though the process is significantly more complicated and the costs higher.
The main legislation and rules governing registration are:
· Part XI of the Act
· Part V of the General regulation to the Act (General Regulation)
· National Instrument 31-103 Registration Requirements and Exemptions (NI 31-103)
· National Instrument 33-109 Registration Information (NI 33-109),and
· National Policy 11-204 Process for Registration in Multiple Jurisdictions (NP 11-204)
All of these can be viewed on the OSC web site at http://www.osc.gov.on.ca. Also, a chart giving details of the categories of registration prior to and after September 28, 2009 when NI 31-103 was implemented, is in Appendix A to CSA Staff Notice 31-311. It can be found at the following link on the OSC web site: http://www.osc.gov.on.ca/documents/en/S ... ndix-e.pdf
The chart starts on page 10 of this 16-page pdf document.
2. Adviser category of registration and proficiency requirements
As noted above, the term "adviser" is defined in subsection 1(1) of the Act, and the requirement for registration of advisers is in subsection 25(3) of the Act. Categories of registration as adviser are in subsection 26(6) of the Act.
Proficiency requirements for individual registrants, including time limits on examination requirements and the requirement for membership in a self-regulatory organization under certain categories, are contained in Part 3 of NI 31-103.
3. Representations that are not permitted
There are specific prohibitions in sections 44 and 46 of the Act that may be relevant to representations made by registrants. For your ease of reference, they are reproduced below:
44. (1) No person or company shall represent that he, she or it is registered under this Act unless the representation is true and, when making the representation, the person or company specifies his, her or its category of registration.
(2) No person or company shall make a statement about any matter that a reasonable investor would consider relevant in deciding whether to enter into or maintain a trading or advising relationship with the person or company if the statement is untrue or omits information necessary to prevent the statement from being false or misleading in the circumstances in which it is made.
46. No person or company shall make any representation, written or oral, that the Commission has in any way passed upon the financial standing, fitness or conduct of any registrant or upon the merits of any security or issuer.
In addition to compliance with the Act, registrants are also required to comply with the rules of the self-regulatory organization (SRO) of which they are a member. This would include the rules of the Investment Industry Regulatory Organization of Canada (IIROC) and the Mutual Fund Dealers Association (MFDA). In addition, individual registrants should be guided by the compliance policies of their sponsoring firms.
4. Other relevant information
Securities law in Canada is regulated by the individual provinces and territories. Although there is considerable harmonization of rules among the provinces and territories, the information in this e-mail is from the perspective of Ontario only. I understand that you are not a resident of Ontario and so you may wish to obtain further information from the securities regulator in your own province. A link to contact information for other provincial regulators is available through the “Contact Us” page of the Canadian Securities Administrators’ website at http://www.securities-administrators.ca. The “Contact Us” link is located at the bottom right-hand side of the CSA’s homepage.
The information in this e-mail is general and should be taken as a guide. The regulation of registration is complex, and the information provided here is not exhaustive of all of the provisions that may apply in specific circumstances. The content is not intended to provide investment, financial accounting, legal, tax or other professional advice and should not be relied upon or regarded as a substitute for such advice.
We recommend that you seek advice from a qualified professional adviser before acting on the information or content appearing in this e-mail or any information or content on a web site to which a link has been provided.
Sincerely,
Jeffrey Fennell
Senior Inquiries Officer
Ontario Securities Commission
inquiries@osc.gov.on.ca
416-593-8314
1-877-785-1555
The information in this e-mail should be taken as a guide. The content is not intended to provide investment, financial accounting, legal, tax or other professional advice and should not be relied upon or regarded as a substitute for such advice. We recommend that you seek advice from a qualified professional adviser before acting on the information or content appearing in this e-mail or any information or content on a web site to which a link has been provided.
larry's followup question Jan 19, 2010:
thank you very much for this information. I hope I can ask you a question or two to clarify a bit.
based on the following:
44. (1) No person or company shall represent that he, she or it is registered under this Act unless the representation is true and, when making the representation, the person or company specifies his, her or its category of registration.
I am interested in finding out how persons who might be registered previously in the category of a "salesperson" or now registered as a "dealing representative" are allowed or permitted to use the name "advisor" when dealing with the public. That seems to contradict the terms of 44 (a) above.
Can you shed any light on this?
thank you very much
larry
To: record@osc.gov.on.ca
Date: 01/17/2010 05:13 PM
Subject: please forward this question to EREZ BLUMBERGER at the OSC
"Erez Blumberger, manager of registrant regulation: Firms or individuals trading or advising must be registered with us."
Erez, from an article recently by Ellen Roseman, I found your name and function.
For similar research and journalistic purposes I too, am trying to determine what registration category is necessary to sell or advise the public on investments. Also I recall a license category titled "advisor" and was wondering if that category still exists and what the qualifications and requirements are to use it?
Would it be possible for you to comment on the two questions above, and comment also on the question of title inflation or advisor representation posed below?
I am trying to answer a question of what an investment person can or cannot represent him or herself as.
Are there any guidelines or rules about what can be represented and what cannot?
thanks much for any help you can be.
Larry Elford
On 19-Jan-10, at 2:36 PM, inquiries@osc.gov.on.ca wrote:
Dear Mr. Elford,
Thank you for your inquiry directed to Erez Blumberger, Manager Registrant Regulation, of the Ontario Securities Commission (OSC). Mr. Blumberger has asked that I review your matter, and respond on his behalf.
1. What registration category is necessary to sell or advise the public on investments?
The appropriate category in which a firm or individual should be registered is entirely dependent on the kinds of services they provide and the products they offer.
In general, a firm must register if they are in the business of trading or advising on securities or if they act as an underwriter or manage an investment fund.
Individuals must register if they trade, underwrite or advise on behalf of a registered dealer or adviser, or act as the ultimate designated person (UDP) or chief compliance officer (CCO) of a registered firm. Individuals who act on behalf of an investment fund manager do not have to register. However, an investment fund’s UDP and CCO must register.
It should be noted that the definition of trade in subsection 1(1) of the Ontario Securities Act (Act) includes activities made in furtherance of a trade, such as any act, advertisement, solicitation, conduct, or negotiation. Other relevant terms, such as “adviser” and “investment fund” are also defined in this subsection. The basic requirement for registration is in section 25 of the Act. Categories of registration are provided in sections 25 and 26 of the Act (for dealer and adviser categories) and in section 7.3 of NI 31-103 (for the investment fund manager category).
Individuals must be sponsored by a firm currently registered in the applicable category with the OSC. It is possible to register your own company as a registrant, though the process is significantly more complicated and the costs higher.
The main legislation and rules governing registration are:
· Part XI of the Act
· Part V of the General regulation to the Act (General Regulation)
· National Instrument 31-103 Registration Requirements and Exemptions (NI 31-103)
· National Instrument 33-109 Registration Information (NI 33-109),and
· National Policy 11-204 Process for Registration in Multiple Jurisdictions (NP 11-204)
All of these can be viewed on the OSC web site at http://www.osc.gov.on.ca. Also, a chart giving details of the categories of registration prior to and after September 28, 2009 when NI 31-103 was implemented, is in Appendix A to CSA Staff Notice 31-311. It can be found at the following link on the OSC web site: http://www.osc.gov.on.ca/documents/en/S ... ndix-e.pdf
The chart starts on page 10 of this 16-page pdf document.
2. Adviser category of registration and proficiency requirements
As noted above, the term "adviser" is defined in subsection 1(1) of the Act, and the requirement for registration of advisers is in subsection 25(3) of the Act. Categories of registration as adviser are in subsection 26(6) of the Act.
Proficiency requirements for individual registrants, including time limits on examination requirements and the requirement for membership in a self-regulatory organization under certain categories, are contained in Part 3 of NI 31-103.
3. Representations that are not permitted
There are specific prohibitions in sections 44 and 46 of the Act that may be relevant to representations made by registrants. For your ease of reference, they are reproduced below:
44. (1) No person or company shall represent that he, she or it is registered under this Act unless the representation is true and, when making the representation, the person or company specifies his, her or its category of registration.
(2) No person or company shall make a statement about any matter that a reasonable investor would consider relevant in deciding whether to enter into or maintain a trading or advising relationship with the person or company if the statement is untrue or omits information necessary to prevent the statement from being false or misleading in the circumstances in which it is made.
46. No person or company shall make any representation, written or oral, that the Commission has in any way passed upon the financial standing, fitness or conduct of any registrant or upon the merits of any security or issuer.
In addition to compliance with the Act, registrants are also required to comply with the rules of the self-regulatory organization (SRO) of which they are a member. This would include the rules of the Investment Industry Regulatory Organization of Canada (IIROC) and the Mutual Fund Dealers Association (MFDA). In addition, individual registrants should be guided by the compliance policies of their sponsoring firms.
4. Other relevant information
Securities law in Canada is regulated by the individual provinces and territories. Although there is considerable harmonization of rules among the provinces and territories, the information in this e-mail is from the perspective of Ontario only. I understand that you are not a resident of Ontario and so you may wish to obtain further information from the securities regulator in your own province. A link to contact information for other provincial regulators is available through the “Contact Us” page of the Canadian Securities Administrators’ website at http://www.securities-administrators.ca. The “Contact Us” link is located at the bottom right-hand side of the CSA’s homepage.
The information in this e-mail is general and should be taken as a guide. The regulation of registration is complex, and the information provided here is not exhaustive of all of the provisions that may apply in specific circumstances. The content is not intended to provide investment, financial accounting, legal, tax or other professional advice and should not be relied upon or regarded as a substitute for such advice.
We recommend that you seek advice from a qualified professional adviser before acting on the information or content appearing in this e-mail or any information or content on a web site to which a link has been provided.
Sincerely,
Jeffrey Fennell
Senior Inquiries Officer
Ontario Securities Commission
inquiries@osc.gov.on.ca
416-593-8314
1-877-785-1555
The information in this e-mail should be taken as a guide. The content is not intended to provide investment, financial accounting, legal, tax or other professional advice and should not be relied upon or regarded as a substitute for such advice. We recommend that you seek advice from a qualified professional adviser before acting on the information or content appearing in this e-mail or any information or content on a web site to which a link has been provided.
larry's followup question Jan 19, 2010:
thank you very much for this information. I hope I can ask you a question or two to clarify a bit.
based on the following:
44. (1) No person or company shall represent that he, she or it is registered under this Act unless the representation is true and, when making the representation, the person or company specifies his, her or its category of registration.
I am interested in finding out how persons who might be registered previously in the category of a "salesperson" or now registered as a "dealing representative" are allowed or permitted to use the name "advisor" when dealing with the public. That seems to contradict the terms of 44 (a) above.
Can you shed any light on this?
thank you very much
larry
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Thu Jan 21, 2010 2:45 pm
oh! my! god!.................I am nearly speechless with the response of the OSC on "advisor" misrepresentation, misinforming the public as to the role and license of persons licensed or acting as salespersons:
Dear Mr. Elford:
Thank you for your follow-up inquiry to the Ontario Securities Commission (OSC) concerning the use of the term "advisor" and how it relates to subsection 44(1) of the Securities Act (Ontario) (the Act).
Ontario securities law does not seek to regulate use of the term advisor in all circumstances. It is a commonly used or generic term. The purpose of subsection 44(1) of the Act is to ensure that people who represent that they are registered under Ontario securities law, do so in a manner that also states their category of registration.
If you have substantive evidence that a person has represented themselves as registered with the OSC but failed to properly disclose their category of registration, we would be pleased to review that evidence. (I have never in thirty years seen anyone disclose their category of registration)
Please note that OSC staff cannot provide you with an interpretation of law or application of the law. If we receive substantive evidence of specific actions that may be in breach of Ontario securities law, that evidence will be reviewed. However, we do not comment on hypothetical situations.
Sincerely,
Jeffrey Fennell
Senior Inquiries Officer
Ontario Securities Commission
inquiries@osc.gov.on.ca
416-593-8314
1-877-785-1555
Dear Mr. Elford:
Thank you for your follow-up inquiry to the Ontario Securities Commission (OSC) concerning the use of the term "advisor" and how it relates to subsection 44(1) of the Securities Act (Ontario) (the Act).
Ontario securities law does not seek to regulate use of the term advisor in all circumstances. It is a commonly used or generic term. The purpose of subsection 44(1) of the Act is to ensure that people who represent that they are registered under Ontario securities law, do so in a manner that also states their category of registration.
If you have substantive evidence that a person has represented themselves as registered with the OSC but failed to properly disclose their category of registration, we would be pleased to review that evidence. (I have never in thirty years seen anyone disclose their category of registration)
Please note that OSC staff cannot provide you with an interpretation of law or application of the law. If we receive substantive evidence of specific actions that may be in breach of Ontario securities law, that evidence will be reviewed. However, we do not comment on hypothetical situations.
Sincerely,
Jeffrey Fennell
Senior Inquiries Officer
Ontario Securities Commission
inquiries@osc.gov.on.ca
416-593-8314
1-877-785-1555
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Sun Jan 24, 2010 11:13 pm
- images.jpeg (3.89 KiB) Viewed 567 times
January 24, 2010
Ellen Roseman
If you lack the time and talent to manage your own investments, you work with advisers who sell mutual funds, stocks, bonds, GICs or insurance-related savings products.
However, except for a small group of fee-paid advisers, most are paid by commissions – and the commissions are higher or lower, depending on the products they sell.
So, how do you trust recommendations that may be tainted by differences in compensation?
How do you know the products you buy are in your best interests or in the adviser's interests?
Investors see financial advisers as on the same level as other professionals – such as doctors, lawyers and accountants – where there are demanding entry requirements, strict codes of conduct and organizations that vigorously enforce standards of behaviour.
It's true that the financial advisory profession is moving in that direction, says Rob Carrick in What's Good, Bad and Downright Awful in Canadian Investments Today (Doubleday, $19.95).
"Generally, though, it's prudent to assume, until proven otherwise, that the person discussing your financial situation is primarily interested in making money by selling you products," he argues.
John Lawrence Reynolds, a critic of the industry, also urges caution in his latest book, The Skeptical Investor (Penguin, $26).
"Financial advisers and brokers are salespeople," he says. "They earn their living by selling things. If they don't sell, they don't eat.
"Some of them are very careful that whatever they sell is suitable for the customer/client they are dealing with and make their decision on that basis.
"Others make their decision exclusively on the size of commission they will earn, and they earn it from your money – no one else's."
Is there a way to deal with the issue of divided loyalties?
Other countries are looking at enforcing a "fiduciary duty" on investment advisers. This means they have an obligation to act in the best interest of the client.
Australia appears headed in that direction after an inquiry last year that looked into the demise of a big company called Storm Financial.
It recommended that financial advisers have a fiduciary duty to place client interests ahead of their own. And it urged regulators to develop a way to ban commissions in consultation with the industry.
In the U.S., a financial services reform bill passed by Congress included a requirement for rules to establish a fiduciary duty for brokers providing investment advice.
Unfortunately, there was one qualifier stuck into the Wall Street Reform and Consumer Protection Act of 2009. It said: "Nothing in this section shall require a broker or dealer or registered representative to have a continuing duty of care or loyalty to the customer after providing personalized investment advice about securities."
This means that the fiduciary standard applies while you work with brokers who are giving you advice. But the moment they act like a broker, suitability is all that matters.
"At the time they give you the advice, therefore, it must be in your best interest," says Chuck Jaffe, a CBS MarketWatch columnist.
"At the time they sell you the securities, however, they no longer have to be acting in your best interest, they need only be selling something suitable."
A fiduciary standard requires more disclosure about possible conflicts of interest and raises the liability stakes for someone providing investment advice. That means greater consumer protection, Jaffe explains.
Next week, what is Canada's position on a fiduciary duty for investment advisers?
eroseman@thestar.ca
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Mon Jan 25, 2010 12:53 pm
Dear Mr Elford,
Thank you for your message.
With regards to your question, under the new National Instrument 31-103 as of September 28, 2009, mutual fund representatives are now called mutual fund dealing representatives and individuals who were an advisor under a portfolio manager are now called an advising representative. Please see this attached link for additional details:
http://www.bcsc.bc.ca/uploadedFiles/sec ... mptions%20[NI].pdf
Thank you,
Kent Waterfield
Senior Registration Administrator
Registration & Compliance Branch
Capital Markets Regulation
British Columbia Securities Commission
Phone: 604 899 6694
Fax: 888 242 9341
800 373 6393 (toll free across Canada)
kwaterfield@bcsc.bc.ca
From: Donna Bobbett On Behalf Of Inquiries
Sent: Monday, January 25, 2010 8:34 AM
To: Kent Waterfield
Cc: Karin R Armstrong
Subject: FW: salesperson, advisor, representative questions for BCSC
The following email is being forwarded to you for direct response.
From: larry elford [mailto:lelford@shaw.ca]
Sent: Friday, January 22, 2010 8:53 PM
To: Inquiries
Subject: salesperson, advisor, representative questions for BCSC
As I read through the various categories of investment industry advisors out there I am confused about what they are licensed as (a bank mutual fund seller for example) and what they are allowed to call themselves, and what they are required to tell me as a fund buyer.
Are they :
1. "advisors"
2. Salespersons
3. registered
4. Dealer registered
I am sorry for the confusing questions, but I am confused by the roles, licenses and titles of those who sell me financial products.
can you clear things up for me?
thanks
larry
Division 3 — Registration — General
Fair dealing with clients
14 (1) A registrant must deal fairly, honestly and in good faith with the clients of the registrant.
(2) A registered
(a) dealing representative, or
(b) advising representative,
of a dealer or adviser must deal fairly, honestly and in good faith with the clients of the dealer or adviser.
[am. B.C. Reg. 226/2009, Sch. C, s. 2.]
Thank you for your message.
With regards to your question, under the new National Instrument 31-103 as of September 28, 2009, mutual fund representatives are now called mutual fund dealing representatives and individuals who were an advisor under a portfolio manager are now called an advising representative. Please see this attached link for additional details:
http://www.bcsc.bc.ca/uploadedFiles/sec ... mptions%20[NI].pdf
Thank you,
Kent Waterfield
Senior Registration Administrator
Registration & Compliance Branch
Capital Markets Regulation
British Columbia Securities Commission
Phone: 604 899 6694
Fax: 888 242 9341
800 373 6393 (toll free across Canada)
kwaterfield@bcsc.bc.ca
From: Donna Bobbett On Behalf Of Inquiries
Sent: Monday, January 25, 2010 8:34 AM
To: Kent Waterfield
Cc: Karin R Armstrong
Subject: FW: salesperson, advisor, representative questions for BCSC
The following email is being forwarded to you for direct response.
From: larry elford [mailto:lelford@shaw.ca]
Sent: Friday, January 22, 2010 8:53 PM
To: Inquiries
Subject: salesperson, advisor, representative questions for BCSC
As I read through the various categories of investment industry advisors out there I am confused about what they are licensed as (a bank mutual fund seller for example) and what they are allowed to call themselves, and what they are required to tell me as a fund buyer.
Are they :
1. "advisors"
2. Salespersons
3. registered
4. Dealer registered
I am sorry for the confusing questions, but I am confused by the roles, licenses and titles of those who sell me financial products.
can you clear things up for me?
thanks
larry
Division 3 — Registration — General
Fair dealing with clients
14 (1) A registrant must deal fairly, honestly and in good faith with the clients of the registrant.
(2) A registered
(a) dealing representative, or
(b) advising representative,
of a dealer or adviser must deal fairly, honestly and in good faith with the clients of the dealer or adviser.
[am. B.C. Reg. 226/2009, Sch. C, s. 2.]
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Tue Jan 26, 2010 9:02 am
- images.jpeg (2.97 KiB) Viewed 556 times
The below are Quebec Court comments about the use of misleading titles by the investment industry to misrepresent themselves to the public in order to earn their trust and get control over their money............which they can then abuse if the so choose, which is often the case when a person is paid by percentage fees or commissions.
(C)MISLEADING TITLES
¶ 263 The defendant attributed to Migirdic fake titles, i.e. "vice-president" and "vice-president and
director", in addition to letting him use the title "specialist in retirement investments". Those titles were
false representations that misled the plaintiffs, hid reality from them, disinformed them, comforted them
in their confidence in Migirdic, reduced their distrust, and contributed to Migirdic's fraud. The
defendant committed a fault in terms of its obligation to inform and advise, in addition to misleading
the plaintiffs.
¶ 264 In principle, a vice-president is a person in a management position in a firm. The
vice-president is immediately below the president and reports to the president. The vice-president acts
in the absence of the president. It is a prestigious title in a firm, a title held by few individuals. The
English word "director", the incorrect origin of the word used here in French, designates either the
member of a board of directors of a firm or the head of a department or office. That is also a prestigious
title, at least when it is attributed in a prestigious firm.
¶ 265 In the defendant's operations, these titles also have that meaning, but not that meaning alone!
They are given as well to any representative (also called an "investment advisor" or previously a
"financial consultant") who reaches a certain level of commissions in a given year, in short, who "sells"
a lot and brings in a lot of commissions. A person is awarded the title essentially in "recognition" of
work and as a marketing tool, as the president of CIBC Wood Gundy, Tom Monahan, acknowledged.
However, to have the title of "vice-president" or "vice-president and director" adds no new
responsibility or any management role. What is more, it testifies to neither greater competence nor
more reliability.
¶ 266 In the defendant's operations, the titles are, in fact attributed to many people. In 1995, there
were 206 vice-presidents and 44 vice-presidents and directors out of 556 representatives. In 1997, there
were 217 vice-presidents and 109 vice-presidents and directors out of 612 representatives. In 1999,
there were 197 vice-presidents and 101 vice-presidents and directors out of 725 representatives, the
proportions were about the same in 2000. That year, about 300 of the 700 representatives had a title!
¶ 267 The problem is that clients do not know that these titles are simply marketing tools, i.e. a
means to convince them that they have an excellent representative, and recognition for the volume of
commissions. Clients therefore believe they have a "very special" and "eminently acknowledged"
representative when the representative has the title of "vice-president" or "vice-president and director".
_____
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Re: Are advisors professionals, or salespeople masquerading?
by admin » Wed Jan 27, 2010 4:22 pm
Dear Mr Elford,
Thank you for your message.
With regards to your questions and comments, you are quite right in that the term "advisor" on its own and used loosely, would be inappropriate for a dealing representative to use without having the educational requirements and experience to be registered as an advising representative.
If you are certain that an individual is holding themselves out inappropriately, please feel free to contact the appropriate securities commission or self regulatory body (Mutual fund Dealers Association or Investment Industry Regulatory Organization of Canada ) through our related links available on our website at: www.bcsc.bc.ca our email is inquiries@bcsc.bc.ca We also have a helpful link on our website called Invest-right , which members of the public can use to assist themselves with their investing.
Thank you,
Kent Waterfield
Senior Registration Administrator
Registration & Compliance Branch
Capital Markets Regulation
British Columbia Securities Commission
Phone: 604 899 6694
Fax: 888 242 9341
800 373 6393 (toll free across Canada)
kwaterfield@bcsc.bc.ca
(advocate comments.........my problem, as I see it is that the securities commissions (BCSC included) are morally blind as evidenced by the fact that NONE of the 130,000 people registered today in the category of "dealing represntative", or yesterday's category of "salesperson" properly identify themselves to the public, and virtually all of them misprepresent themselves as "advisors". It is in every newspaper, every day, on every advertisement, etc., and for the BCSC to ignore this is the ultimate in "see no evil" behavior) Having spent many years of my life already trying to point out rules broken and laws ignored by these very same regulators, what would be the point of letting this person in on the moral blindness? Can anyone tell me the correct solution? Please?)
Thank you for your message.
With regards to your questions and comments, you are quite right in that the term "advisor" on its own and used loosely, would be inappropriate for a dealing representative to use without having the educational requirements and experience to be registered as an advising representative.
If you are certain that an individual is holding themselves out inappropriately, please feel free to contact the appropriate securities commission or self regulatory body (Mutual fund Dealers Association or Investment Industry Regulatory Organization of Canada ) through our related links available on our website at: www.bcsc.bc.ca our email is inquiries@bcsc.bc.ca We also have a helpful link on our website called Invest-right , which members of the public can use to assist themselves with their investing.
Thank you,
Kent Waterfield
Senior Registration Administrator
Registration & Compliance Branch
Capital Markets Regulation
British Columbia Securities Commission
Phone: 604 899 6694
Fax: 888 242 9341
800 373 6393 (toll free across Canada)
kwaterfield@bcsc.bc.ca
(advocate comments.........my problem, as I see it is that the securities commissions (BCSC included) are morally blind as evidenced by the fact that NONE of the 130,000 people registered today in the category of "dealing represntative", or yesterday's category of "salesperson" properly identify themselves to the public, and virtually all of them misprepresent themselves as "advisors". It is in every newspaper, every day, on every advertisement, etc., and for the BCSC to ignore this is the ultimate in "see no evil" behavior) Having spent many years of my life already trying to point out rules broken and laws ignored by these very same regulators, what would be the point of letting this person in on the moral blindness? Can anyone tell me the correct solution? Please?)
- admin
- Site Admin
- Posts: 1506
- Joined: Fri May 06, 2005 9:05 am
- Location: alberta
Return to Click here to view forums
Who is online
Users browsing this forum: No registered users and 1 guest