Bourque reports that regulators concluded a full ban would push advisors toward explicit account fees that small investors would be less able and willing to pay, undermining access to advice.
Instead, they targeted abuses by banning embedded commissions in DSC funds, prohibiting embedded payments to order‑execution‑only dealers, and tightening disclosure and conflict‑of‑interest rules.
By contrast, the e‑brief notes that the UK, Australia and the EU (for non‑bank distributors) banned embedded commissions, then struggled with gaps in access for less affluent investors.
According to Bourque, these experiences underline how hard it is to restore limited advice for modest investors once regulators dismantle the compensation model that supported it.
The paper closes with three main takeaways for policymakers: seriously examine CIRO‑style self‑regulation for insurance distribution; put more weight on competition and efficiency, not just consumer protection, when designing rules; and run fuller, more realistic consultations so new regulations are both necessary and implementable.
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