Re: Structure of Securities Regulation in Canada

RBC Financial Group welcomes the opportunity to provide our views on improving the securities regulatory system in Canada.

We believe that the time finally is right to make significant improvements to the efficiency and effectiveness of our securities regulatory system. A number of recent studies and reports clearly demonstrate the unnecessary costs, inefficiencies and duplication that are built into our current system. That it has worked as well as it has is a credit to the extensive efforts and cooperative spirit of the many regulatory authorities involved - but we can do better.

We recognize that the process of improving our securities regulatory system will require the cooperation of key stakeholders, including different levels of government. We are encouraged that the political will to achieve reform has become increasingly evident at all levels and support a cooperative intergovernmental process to achieve a national securities regulatory system for Canada.

We strongly support the harmonization initiatives undertaken to date and planned by the Canadian Securities Administrators, as well as the passport system recently proposed by the provincial Ministerial Committee. These initiatives will help to improve the efficiency of our current securities regulatory system; but they should be viewed only as incremental and not the end point. In our view, a national regulator supported by uniform governing legislation represents the best model to achieve the reform Canada deserves.

There are a number of models under discussion to achieve the reform required, but in our view, regardless of the model selected, the end point must be an efficient, cost-effective and responsive regulatory system that can help our businesses and capital markets remain relevant and competitive from a global perspective. What we would not wish to see is simply another layer of regulation, without accompanying simplification and efficiency.

We look forward to receiving your Committee's recommendations and would be pleased to participate further in your consultation process. Please feel free to contact the undersigned by e-mail at or by telephone at 416.955.3592 if you have any questions with respect to our letter.

RBC Law Group