The IIAC was pleased to offer comments on British Columbia Securities Commission (BCSC) Notice 2018/01 – Consulting on the Securities Law Framework for Fintech Regulation (the “consultation paper”). The IIAC appreciates input received from members, industry experts and Fintech firms.

Fintech has the potential to add efficiencies and introduce a new competitive element to the industry, as well as fundamentally change the structure of the industry insofar as how firms, clients, vendors, and regulators interact. As innovation progresses, regulation needs to keep pace in order to facilitate business operations.

In this regard, the IIAC recommended that regulators:

– Take a very broad view of the regulatory landscape as it applies to all entities providing financial services to clients (including those outside the jurisdiction of provincial regulators), rather than the current silo’d approach to the delivery of services.

– Impose consistent regulatory standards on entities that undertake (digitally or manually) the same or similar activities, be they a registered firm or Fintech provider. This may necessitate imposing existing regulation on Fintech providers for certain functions, or reducing the regulatory burden for existing registrants for certain functions, to ensure a level playing field.

Allowing for more automated solutions to permit clients to move between the digital and traditional advice platforms would ultimately increase accessibility of advice, as it would reduce the friction between platforms by reducing dealer cost and investor inconvenience associated with starting from scratch with a new advisor on a different platform.

The IIAC provided additional comments on matters such as crowdfunding, digital advice, cryptocurrency and Initial Coin Offerings (ICOs).

For more information, read our submission, or contact Susan Copland, scopland@iiac.ca.