Re: - Blueprint for A Canadian Securities Commission

Dear Mr. Crawford,
Allow me to introduce myself, I'm the immediate past president of the FCIDB and responding to your letter February 17, 2007, originally addressed to Orville Sleen, our then Executive Director.
As background, and on my watch, the executive committees have spearheaded the evolutionary changes of a deposit broker/agent trade group into a Professional Standards Organization. Going forward and within that orbit, a task force has been charged with structuring an industry wide voluntary compliance and oversight regime. Furthermore, in response to marketplace neglect, we had orchestrated a successful public campaign to move the government of the day into raising Canada Deposit Insurance Corporation deposit protection limit to its present level of $100,000.00.
The FCIDB membership is composed of some 80 plus independent financial firms and their respective representative financial advisors, - from home based local trusted advisors through to large nation branded financial services groups. The FCIDB is also unique in that 36 financial institutions also hold membership and are represented at board level.

From inception, our founding members' modus operandi still resonates - in that the clients' interest is the first objective.
That said, the advent and tsunami type of tidal wave of new rules and regulations from the individual provincial securities regulators, self-regulatory provincial and federal bodies (SROs), coupled with compliance requirements of such Acts administered by FINTRAC and that of PIPEDA - all of which are interpreted or in some instances misinterpreted through a plethora of institutions compliance or legal departments - has created confusion and stress on our members and their clients.
It's commendable that your imaginative treatment of the complex Canadian securities landscape has been fashioned into a simple workable formula - congratulations. However, it should be noted that the weight of all new and or added responsibilities applied through licensing or agency contracts and agreements, has the individual independent advisor - in my personal opinion, at the blunt end and by default, ultimately accountable for all that ails the financial system as we see it today. Moreover the trusted advisor relationship with the consumer is being strained beyond any reasonable expectation of sustainable services levels, as profitability benchmarks move higher to accommodate the aforementioned, the consumer is thus marginalized, neglected or abandoned - this undesirable disservice needs to be openly identified and remedied.

Moving forward, every effort should be made at the legislative or regulatory level to provide sufficient mechanisms, information tools, public awareness protocols and implementation and impact consultation with the advisor and the consumer.

To reiterate, we as an organization, and our individual independent deposit brokers members, wholeheartedly support your arguments for a principled based single regulatory body as found within other sophisticated financial capital markets.

Our single and foremost concern is that the impact of such fundamental change will have an untimely impact on the consumer of such financial services or products, and those trusted advisors will be sandwiched between legislative subsections, otherwise known as the provable rock and a hard place - a significant aspect easily overlooked when competing regulative institutions vie for marketplace authority.
I thank you for your invitation and the opportunity to provide our support behind this initiative.

Yours truly

David J. Newman
Immediate Past President
Federation of Canadian Independent Deposit Brokers
49 High Street, Suite 408-2
Barrie, On L4N 5J4
(705) 730-7599

C.C. Stephen Harper, Prime Minister, James M. Flaherty, Minister of Finance
including provincial and territorial premiers and ministers of finance and securities regulators.