Notice of rule and request for comment on FP/FA fees consultation

Introduction 

Pursuant to subsection 22(1) of the Financial Services Regulatory Authority of Ontario Act, 2016 (the FSRA Act), the Financial Services Regulatory Authority of Ontario (FSRA) is publishing for comment proposed amendments to Rule 2019-001 – Assessments and Fees (the FSRA Fee Rule).

With this Notice, FSRA is proposing changes to the FSRA Fee Rule that would establish the fee structure for the financial professionals sector under the Financial Professionals Title Protection Act, 2019 (FPTPA).

The proposed amendments to the FSRA Fee Rule (Amendment 1) are set out in Appendix A to this Notice. Interested persons are invited to make written representations to FSRA with respect to proposed Amendment 1 by October 20, 2021.   

We have included questions in the Stakeholder Engagement section of this Notice for consideration and comment. These questions are also summarized at the end of this Notice.

Background

FSRA’s goal for implementing the Financial Planner/Financial Advisor (FP/FA) title protection framework is to mitigate consumer confusion and provide confidence to consumers and investors that the individual with whom they are dealing is qualified to provide financial planning or advisory services. 

FSRA will achieve this by implementing a fair and flexible framework that leverages existing regimes for granting and supervising financial planning and advising designations and licences to ensure that individuals using the FP or FA titles meet minimum standards. 

The FSRA Fee Rule, which came into force in 2019, prescribes the fee structure for FSRA’s regulated sectors. The proposed financial professionals fee structure will be incorporated into the FSRA Fee Rule and align with the principles and methodologies outlined within.

To establish the FP/FA title protection framework, FSRA posted proposed Rule 2020-001 – Financial Professionals Title Protection (the FPTP Rule) for public consultation in August 2020 and reposted an amended version for consultation in May 2021. During both consultations, FSRA solicited comments about fees and a proposed fee structure for the title protection framework. Stakeholders highlighted the following key themes with respect to fees:

• Concerns that individuals holding multiple approved credentials could potentially pay more than one fee under the framework.
• FSRA should clarify the criteria used to define “credential holder” with respect to calculating fees (e.g., residency in the province, where the individual conducts business, use of title).​
• FSRA should not define “credential holder” and should allow approved credentialing bodies (CBs) the flexibility to determine who is considered a credential holder/fee-paying individual. ​
• Scope for proposed fee structure to disadvantage smaller organizations that may seek approval as CBs.

These themes are discussed throughout this Notice and will be considered as part of the finalization of the proposed fee structure.

Substance and purpose of the Rule

Proposed financial professionals fee structure: vision and principles

To enable implementation of the title protection framework, FSRA must establish a fee structure that supports its mandate to operate as an independent, self-funded regulator.

The proposed financial professionals fee structure would:  

• enable the recovery of costs incurred to design and implement the framework; 
• enable the recovery of ongoing regulatory costs for overseeing the financial professionals sector; and  
• not introduce undue burden on individual credential holders and potential CBs.  

FSRA’s approach to designing the title protection framework is to leverage existing standards and regimes already in the marketplace. This allows for existing licences and designations to be recognized as meeting the minimum standards for title usage, and to enable certain individuals to continue to conduct business using the FP/FA titles without significant disruption or additional costs.

FSRA heard from stakeholders that the fee structure for the framework should minimize the need for CBs to introduce new technology or procedures to collect fees from individual credential holders. The proposed financial professionals fee structure seeks to minimize additional burden and costs for potential CBs, by allowing CBs to leverage their existing administrative and operational processes to pay relevant fees to FSRA.

FSRA has used the same principles, as applied to develop the FSRA Fee Rule, to design the proposed financial professionals fee structure. The objective was to establish a simple, consistent and fair approach to assessments and fees charged, as done in the other regulated sectors.

The proposed financial professionals fee structure aligns with the principles outlined below.

Methodology

The proposed financial professionals fee structure has been designed based on the estimated resources required to fulfill FSRA’s regulatory requirements under the FSRA Act, while enabling FSRA’s continued transformation into a principles-based, independent and transparent regulator through its priorities and operating activities.

Costs are being accrued for the financial professionals sector to ensure that other sectors are not bearing the costs of establishing the title protection framework. These costs will be recovered from the sector once regulation commences and the proposed fee structure is implemented.

FSRA projects its financial activities for each fiscal year as part of its Proposed Statement of Priorities and Budget. Each Fall, FSRA consults on the proposed priorities and budget with members of FSRA’s Stakeholder Advisory Committees, who have the opportunity to meet with FSRA management and the Board of Directors and provide feedback. FSRA also posts the document for public consultation. Following feedback received, the priorities and budget are finalized in FSRA’s Annual Business Plan and submitted to the Minister of Finance for approval.

The proposed financial professionals fee structure will enable the recovery of FSRA’s “direct” and “common” costs for the sector as outlined each year in the FSRA budget.

Direct costs are those directly related to FSRA’s regulatory activities for overseeing the sector, such as:

• Market Conduct, Legal and Policy costs, including, but not limited to, monitoring and supervision of approved CBs, complaints handling, etc.
• Other direct costs associated with regulatory oversight of the sector, such as consumer education activities.

Common costs are costs borne by FSRA that are not directly related to the regulatory oversight of the sector, including, but not limited to:

• Information Technology
• Corporate Services
• Public Affairs
• Other shared costs (e.g., through the allocation of common costs, the financial professionals sector will contribute to the costs associated with FSRA start-up)

Common costs are allocated proportionately amongst all FSRA regulated sectors based on the overall direct costs.

A full listing of direct and common costs is available as part of the FSRA budget consultation process.

Proposed financial professionals fee structure

FSRA is proposing the following fees under the title protection framework:

• Application Fees
• Annual Assessment, comprised of three components:
  • Fixed Annual CB Fee
  • Variable Annual CB Assessment
  • Time-limited Annual Assessment to Recover Start-up costs

Clauses 21(2)(b) and 21(2)(d) of the FSRA Act authorizes FSRA to make rules governing fees, including application fees.

Application fees

Credentialing body

FSRA will require a fee to be paid upon the submission of an application for the approval of a CB under the FPTPA.

The application fee for the approval of a CB is non-refundable and must be paid upon the submission of the corresponding application form.

FSRA is proposing a $10,000 fee for an application for approval of a CB. The proposed application fee will recover the direct costs associated with reviewing an application for approval of a CB (e.g., the estimated amount of time FSRA staff will spend reviewing the application).

FP/FA credentials

FSRA will require a fee to be paid upon submission of an application for the approval of an FP or FA credential under the FPTPA.

The application fee for the approval of each FP or FA credential is non-refundable and should be paid upon submission of the corresponding application. For example, should an entity wish to obtain approval to offer both an FP and an FA credential, the entity must submit one application fee for the FP credential and one application fee for the FA credential.

FSRA is proposing a $5,000 fee for each credential application. The proposed application fee will recover the direct costs associated with reviewing an application for approval of a credential (e.g., the estimated amount of time FSRA staff will spend reviewing the application).

The proposed application fees meet the vision and principles as outlined above, in particular:

1. Fairness
   • The proposed application fees are proportionate to the work effort required to review an application.
2. Future Focus
   • Setting a fixed application fee may result in the proposed application fees being out of step with actual costs in the future. However, FSRA anticipates the risk will not be significant given the number of applications that are anticipated after the first year is expected to be low.  
3. Simplicity
   • A fixed application fee is simple for applicant CBs to calculate and for FSRA to administer.
4. Consistency
   • Application fees are reasonable and the same for all sizes and business models of potential applicant CBs so should not to deter any potential applicant.
5. Transparency
   • Fixed application fees will be set out in a Rule.
6. Effectiveness and efficiency
   • FSRA has proposed separate application fees for approval of CBs and credentials to reflect the likely volume of FP/FA credentials entering the framework, both at the time of implementation and in the future.

Annual assessment

In order to recover costs related to FSRA’s regulatory activities (i.e., direct and common costs) for the financial professionals sector, FSRA is proposing an annual assessment fee. The assessment is comprised of three components:

• Fixed Annual CB Fee
• Variable Annual CB Assessment
• Time-limited Annual Assessment to Recover Start-up costs

The proposed assessments will support FSRA’s infrastructure for oversight of CBs and the monitoring of individuals who use the FP/FA titles without an approved credential.

FSRA has included an assessment-based calculation as part of the annual assessment fee to ensure the recovery of budgeted expenses in a fair and equitable manner.

Fixed annual CB fee

Regardless of their size or complexity, all approved CBs will require a minimum level of oversight. The proposed fixed annual CB fee supports the recovery of direct costs incurred for oversight of the sector. FSRA is proposing $25,000 for the fixed annual CB fee.

Variable annual CB assessment

FSRA anticipates that it will cost approximately $1.1 million annually to oversee the FP/FA sector (approximately $600,000 in direct costs and $500,000 in common costs).

The proposed variable annual CB assessment will recover the following:

1. Direct costs for the assessment period that are not otherwise recovered from the fixed annual CB fee and application fees; and
2. FSRA common costs allocated to the financial professionals sector, then among approved CBs in proportion to their share of the total number of credential holders in the sector.

FSRA is proposing that such direct and common costs be allocated based on the benefit received by the CB under the title protection framework. The number of credential holders is a suitable proxy to establish the benefit received from an effective title protection framework, as it accrues equally to all credential holders.

FSRA proposes to assess approved CBs for the variable annual assessment by allocating the total budgeted expenses of the sector for the assessment period, net of budgeted fixed fees, among CBs in proportion to their share of the total number of credential holders in the sector.  

Time-limited annual assessment to recover start-up costs

FSRA will need to recover costs incurred to design and implement the title protection framework up to March 31, 2022^[1] (“start-up costs”). These costs are identified in the 2020/21 and 2021/22FSRA budgets at approximately $3.1 million.

FSRA is proposing to allocate start-up costs among approved CBs in proportion to their share of the total number of credential holders in the sector. This approach will result in CBs with a larger number of credential holders paying a higher portion of the start-up costs.

FSRA proposes to amortize start-up costs over a 5-year period. Approved CBs will be assessed each year for five (5) years based on the unrecovered amount of start-up costs.

The proposed approach would support FSRA’s principles, as the activities related to the design and implementation of the framework benefit all credential holders in the same manner.

FSRA is proposing a flexible approach to recovering start-up costs. Should new CBs enter the framework during the 5-year amortization period, the start-up cost assessments would be adjusted, as determined appropriate by FSRA, to ensure that new CBs pay their proportionate share of start-up costs and that previously approved CBs are compensated for any overpayment. Such adjustment is intended to reasonably ensure that if additional CBs are approved after FSRA has started collecting fees and assessments, start-up costs are fairly allocated amongst CBs over the 5-year amortization period.

Table 1

CBs could expect to pay within the following range^[2]:

The estimated costs outlined in Table 1 could result in a combined annual average^[5] cost of $22 per credential holder for the first five (5) years^[6] of the framework to recover both the estimated ongoing annual regulatory costs and the year one portion of start-up costs.

The total annual assessment payable by a CB will be set out in an annual invoice delivered to the CB by FSRA. FSRA will invoice approved CBs in advance for the assessment period (fiscal year April 1 to March 31). Invoices will be issued just after the beginning of the fiscal year.

The proposed annual assessment meets the vision and principles as outlined above, in particular:

1. Fairness
   • Costs are, after taking into account the minimum estimated costs to supervise any CB, allocated based on a CB’s proportion of credential holders.
   • The assessment-based formula provides for applicant CBs to pay their fair share of start-up costs based on the benefit they will receive from operating under the framework.
   • Flexible approach to recovering start-up costs mitigates the potential for entities to delay application in order to avoid paying the additional assessment.
   • CBs would pay an equal amount into the recovery of costs incurred as a result of regulating the sector to support the recovery of direct costs.
2. Future Focus
   • Variable annual assessment is based on FSRA’s budgeted amounts.
   • Recovery of start-up costs will ensure that FSRA is financially able to carry out its mandate as a financial services regulator.
   • The fixed annual CB fee will contribute to the recovery of FSRA’s budgeted direct costs.
3. Simplicity
   • Amounts payable will be set out in an annual invoice.
4. Consistency
   • Variable annual assessment will only vary based on the extent that FSRA’s budget and a CB’s number of credential holders change each year.
5. Transparency
   • Calculation formulas will be set out in a Rule.
   • Costs to regulate the sector will be set out in the annual FSRA budget.
   • FSRA budget is subject to a transparent consultation and comment process.
6. Effectiveness and efficiency
   • Assessment formula based on budgeted costs.
   • Amortization of the start-up costs lessens the financial impact for applicant CBs in order to enter the framework.
   • Minimum annual fee that supports work related to direct oversight of CBs will be similar for each entity.

Stakeholder engagement

Since Fall 2019, FSRA has been consulting with key stakeholders on the development of the title protection framework.

From August to November 2020, as part of the 90-day public consultation on the proposed FPTP Rule, FSRA requested comments with respect to a fee structure for the title protection framework, including whether it allowed for fair cost recovery, or if there were any operational challenges that CBs could foresee with such a fee structure.

In the second public consultation released in May 2021, FSRA included a high-level summary of the proposed financial professionals fee structure.

FSRA received comments and suggestions about fees during both public consultation periods. Several common themes were identified, which FSRA took into consideration when designing the proposed fee structure:

1. Collection of fees from credential holders

A number of stakeholders expressed concerns with the requirement for CBs to collect fees from credential holders, as they felt it could present significant operational challenges. Some organizations advised that they did not currently have the capacity to collect a separate and distinct fee from credential holders to support the title protection framework.

The proposed fee structure does not require CBs to collect fees from individual credential holders, instead allowing CBs to recoup their costs in the manner which best suits their business needs. This proposed approach addresses stakeholder concerns and allows FSRA to recoup its costs in a fair and flexible manner.

In April 2021, amendments to the FSRA Act and the FPTPA received Royal Assent, providing FSRA with clear rule-making authority to establish the proposed financial professionals fee structure^[7].

2. Fee calculation – credential holder variable

The proposed financial professionals fee structure uses an assessment-based calculation to determine a CB’s annual assessment. This includes allocating a portion of costs according to each CB’s proportion of credential holders.

Several stakeholders suggested that FSRA should determine fees based on the number of title users, as not all credential holders may decide to use the FP/FA titles. It was further suggested that individuals not benefiting from the framework should not be required to pay a fee.

Other organizations advised that it would not be possible to implement new procedures that would identify credential holders that use the FP/FA titles without additional administrative burden.

Prior to finalizing the proposed fee structure, FSRA is seeking feedback on how it should apply the “credential holder” variable. For example, the number of credential holders could be determined based on whether a person:

1. resides in Ontario
2. conducts business in Ontario
3. holds an approved credential
4. uses the FP or FA title
5. a combination of the above factors

It has been suggested that approved CBs should have the discretion to identify credential holders in a manner that best suits their business needs and operations. For example, a CB could create a sub-designation within its membership, which could be submitted for approval to FSRA as an FP/FA credential. In this scenario, use of the FP/FA titles would be limited to those individuals who hold the designation that has been approved by FSRA. FSRA is seeking feedback on this potential approach.

FSRA is seeking feedback on the potential impact of these potential approaches, including with respect to the collection of data regarding residency, title use, or business conduct of credential holders.

3. Potential for multiple fees

As a result of the framework, there may be scenarios in which some credential holders may be subject to additional fees/costs.

During both consultations, several stakeholders commented that FSRA should not establish a fee structure that would result in individuals having to pay additional fees. More specifically, stakeholders suggested that individuals registered with a Self-Regulatory Organization (SRO), such as the Mutual Fund Dealers Association of Canada (MFDA) and the Investment Industry Regulatory Organization of Canada (IIROC), should be exempt from paying fees, or should pay a reduced fee, under the framework.

It is anticipated that implementation of the title protection framework will cost a combined annual average cost of approximately $22 per credential holder for the first five (5) years  of the framework^[8].

The proposed financial professionals fee structure does not allow individuals to be exempt from paying a fee if they hold more than one approved credential, or if they are already overseen by an SRO. FSRA has designed the proposed fee structure to impose fees on CBs, giving them discretion as to how they recoup any administrative or operational costs associated with the requirements to participate under the framework. Providing a fee exemption for individual credential holders may put some approved CBs at a disadvantage, as it may limit their means to recoup those costs.

The impact to individual credential holders who may hold more than one approved credential would be determined by their CB and their approach to recoup their costs.

FSRA is seeking feedback on how its proposed approach may impact individual credential holders.

Concerns were also raised about credential holders being subject to multiple fees across multiple jurisdictions, once other title protection frameworks have been implemented across Canada. FSRA will engage with other Canadian regulators to discuss how fees and processes could be harmonized to minimize any potential financial impact on credential holders.

4. Impact on consumers

Several stakeholders commented that FSRA should keep fees as low as possible to avoid unintended consequences, such as deterring individuals from title use or consumers potentially losing access to financial planning and advisory services.

Some stakeholders also suggested that the implementation of the title protection framework may lead to consumers paying higher fees in order to offset any additional fees that credential holders may be required to pay under the framework.

Based on the estimated annual fees outlined in Table 1, it is expected that a CB’s cost per credential holder will be low (combined annual average cost of approximately $22 for the first five (5) years^[9] of the framework) and it is unlikely that fees to individual credential holders will increase significantly as a result of implementing the framework. However, CBs may incur additional costs to improve their processes and oversight functions in order to obtain FSRA approval as a CB, some of which could be passed on to credential holders.

Overall, FSRA does not anticipate any additional material costs to consumers. More information on the estimated monetary impact on individual credential holders is discussed in the Anticipated Costs and Benefits section of this Notice.

5. Transparency of fees

Some stakeholders suggested that FSRA should require CBs to clearly itemize or delineate their fees, so that credential holders understand how much of their renewal/recertification will go to FSRA.

While approved CBs should ensure that their credential holders understand the costs associated with the title protection framework, FSRA has not prescribed a practice or process that CBs must follow with respect to renewal/recertification fees.

As part of its regulatory activities, FSRA will monitor the conduct of approved CBs under the framework and determine whether additional guidance and/or a change to relevant Rule(s) would be necessary to prevent misleading or false behaviour with respect to fees.

In addition to CB oversight, FSRA will also need to build and implement other common functionalities, such as a public registry. FSRA will also require an oversight framework to address unauthorized title use. The costs to operate these activities could change over time.

6. Potential disadvantage for smaller entities

During the May 2021 consultation on the proposed FPTP Rule, some stakeholders commented that the proposed fee structure could disadvantage smaller entities or prevent them from entering the framework as CBs. In particular, stakeholders have commented that the proposed $25,000 fixed annual CB fee is too high.

The proposed fee structure seeks to balance the cost of overseeing the sector with the benefit of participating in the framework. FSRA expects there will be a minimum level of oversight required for all approved CBs, regardless of their size or complexity. The proposed fixed fee seeks to recover a portion of FSRA’s costs related to directly overseeing the sector and allocate those costs fairly among approved CBs.

FSRA is seeking feedback on the potential impact of the proposed fixed fee amount on smaller entities’ ability to enter the framework as CBs.

Summary of proposed changes to the FSRA fee Rule

It is proposed that the FSRA Fee Rule be amended by:

(a)  adding a definition of “financial professionals sector” and amending the definitions of “regulated sector” and “variable rate sectors”;

(b) adding a new Part 8 that prescribes the assessments and fees for the financial professionals sector; and

(c) re-numbering certain parts and sections of the rule.

Authority to establish FP/FA fees

The following statutory provisions give FSRA authority^[10] to make the proposed changes to the FSRA Fee Rule:

• Subsection 21(1) of the FSRA Act authorizes FSRA to make rules in respect of any matter over which a statute gives FSRA rule-making authority.
• Subsection 21(2) of the FSRA Act authorizes FSRA to make rules governing fees, levies, sector assessments and other charges FSRA may impose for applications for approvals, and in connection with work that relates to FSRA’s objects under sections 3 and 3.1 of the FSRA Act.
• Section 3.1 of the FSRA Act prescribes that an object of FSRA is to administer and enforce the FPTPA.

Anticipated costs and benefits

As this is a new initiative, the title protection framework will result in new costs for sector participants.

The proposed fee structure could result in a combined annual average cost of $22 per credential holder for the first five (5)^[11] years of the framework to fund a CB’s annual fee.

The proposed financial professionals fee structure will result in a new annual fee for organizations wishing to apply for approval as a credentialing body under the FPTPA. It will also result in additional fees over the first five (5) years of implementation to fund the recovery of start-up costs incurred to design and implement the title protection framework. Illustrative examples of these fee ranges are provided above.

FSRA has designed the proposed fee structure to allow for flexibility to enable potential CBs to recoup costs related to the title protection framework in such ways as they see fit.

The proposed fee structure supports the implementation of the title protection framework and would result in the following benefits:

• Minimizes additional burden and costs for potential CBs by allowing CBs to leverage their existing administrative and operational processes to pay relevant fees to FSRA.
• Amortization of the proposed start-up costs lessens the financial impact for potential CBs to enter the framework.
• Ensures the recovery of budgeted expenses in a fair and equitable manner.
• Stakeholders will have an opportunity to comment on the proposed budget during the public consultation process.

Other potential benefits of the proposed fee structure have been discussed in various sections throughout this Notice.

Alternatives considered

FSRA considered several alternatives with respect to developing the financial professionals fee structure. Some of these alternatives are discussed in the Stakeholder Engagement section of this Notice.

In addition, FSRA also considered the following alternatives:

1. Fixed annual CB fee

The proposed fee structure includes, in addition to a fixed annual fee, a variable annual assessment. This approach aligns with assessment-based fee calculations for other FSRA-regulated entities, such as insurance companies, pension plans and credit unions. As this is a new sector, accurately forecasting costs would be challenging. An assessment-based calculation provides the necessary flexibility to set fees each year in a transparent process so that FSRA can collect necessary revenues to ensure the effective operation of the framework.

FSRA considered whether a single fixed fee would be more appropriate, similar to fixed renewal fees charged to mortgage brokerages and insurance agents.

However, a single fixed annual fee does not align with FSRA’s principles for designing the proposed financial professionals fee structure. While a single fixed fee may be sufficient to recover costs in the short-term, it does not take into account any future increases/decreases to FSRA budgeting or regulatory activities, which could lead to a shortfall in cost recovery. A single fixed fee also does not support the principle of fairness, as costs that are not directly associated with regulating the financial professionals sector would be allocated in a manner that is not based on benefit.

Each year, FSRA posts its Proposed Statement of Priorities and Budget for consultation. Following feedback received, the priorities and budget are finalized in FSRA’s Annual Business Plan and submitted to the Minister of Finance for approval.

2. No amortization of FSRA start-up costs

The proposed fee structure includes the amortization of the proposed start-up costs over five (5) years.

FSRA considered establishing the fee structure without amortization. This would have resulted in approved CBs paying a significant amount upon entry into the framework. In addition, it could have created an incentive for potential CBs to wait until others had paid the full amount of start-up costs, effectively avoiding the requirements to pay their fair share upon establishment of the framework.

FSRA understands that the existing landscape of licensing and designation providers is diverse, and not all potential CBs may have the capacity to pay the entire amount of start-up costs upon approval. FSRA is also aware that other Canadian jurisdictions may implement similar title protection frameworks within a similar timeframe.

Unpublished materials 

FSRA has not relied on any significant unpublished study, report, decision, or other written materials, other than internal reports prepared by FSRA management for the FSRA Board of Directors. 

Regulations to be revoked 

FSRA is not currently making any recommendations with respect to the amendment or revocation of a regulation or provision in a regulation that relates to the implementation of proposed Amendment 1. 

Text of revised Rule 

For the text of proposed Amendment 1 to the FSRA Fee Rule, please see Appendix A. 

Summary of questions for consideration and comment

Fee calculation – credential holder variable

1. Prior to finalizing the proposed fee structure, FSRA is seeking feedback on how it should apply the “credential holder” variable. For example, the number of credential holders could be determined based on whether a person:

• resides in Ontario
• conducts business in Ontario
• holds an approved credential
• uses the FP or FA title
• a combination of the above factors

2. It has been suggested that approved CBs should have the discretion to identify credential holders in a manner that best suits their business needs and operations. For example, a CB could create a sub-designation within its membership, which could be submitted for approval to FSRA as an FP/FA credential. In this scenario, use of the FP/FA titles would be limited to those individuals who hold the designation that has been approved by FSRA. FSRA is seeking feedback on this potential approach.

3. FSRA is seeking feedback on the potential impact of these potential approaches, including with respect to the collection of data regarding residency, title use, or business conduct of credential holders.

Potential for multiple fees

4. FSRA is seeking feedback on how its proposed approach may impact individual credential holders.

Potential disadvantage for smaller entities

5. FSRA is seeking feedback on the potential impact of the proposed fixed fee amount on smaller entities’ ability to enter the framework as CBs.

Comments 

Interested parties are invited to make written representations with respect to proposed Amendment 1 to the FSRA Fee Rule. Submissions received by October 20, 2021 will be considered.

Submissions should be submitted through the submission system on FSRA’s website. 

Under the FSRA Act, FSRA is required to make all written representations publicly available. As a result, all submissions received will be posted on FSRA’s website in a timely manner. 

Appendix A – proposed amendment 1 – Rule 2019-001 – fees and assessments

• Rule 2019-001 Fees and Assessments

 

---