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1 Advocis 390 Queens Quay West, Suite 209 Toronto, ON M5V 3A2 T F July 15, 2014 Ms. Jane Rooney Financial Literacy Leader Financial Consumer Agency of Canada 427 Laurier Ave. West, 6 th Floor Ottawa, ON K1R 1B9 Dear Jane, Thank you once again for the opportunity to participate in the Stakeholder Consultation on Strengthening Seniors Financial Literacy in Ottawa on June 17, The discussion was very encouraging given that many participants expressed similar or consistent views. Our comments are focused on the important role of professional financial advisors in helping to strengthen seniors financial literacy. In addition, responses are provided to the questions posed in the proposed blueprint. Advocis, The Financial Advisors Association of Canada, is the association of choice for financial advisors and planners. With more than 11,000 members across the country, Advocis is the definitive voice of the profession, advocating for professionalism and consumer protection. Professional financial advisors and planners are critical to the economy, helping consumers make sound financial decisions that ultimately lead to greater financial stability and independence. Advocis works with decision-makers and the public, stressing the value of financial advice and striving for an environment in which all Canadians have access to the advice they need. Advocis members are provincially licensed to sell life and health insurance, mutual funds and other securities. Most of our members are credentialed with a recognized industry designation such as CFP, CLU, CH.F.C., CHS. Advocis members offer wide ranging financial advice for Canadian consumers; individuals of all ages, families and small business owners. Those who are near retirement or retired make up a significant segment of our members client base. On page 13 of the proposed blueprint it was noted that senior s, Inabilities to access and/or afford relevant financial advice interferes with their development of financial literacy. 1

2 Advocis members (Financial Advisors) provide financial advice to a wide range of Canadians, not just those with investible assets. As a result, financial advisors are uniquely positioned to help. With all clients, including seniors -- the client conversation starts with the identification of goals and objectives. It s a listening exercise that often results in the client saying; no one ever asked me that before or I ve never told anyone that. By nature, people are not open about their financial situation. As a result, trust is critical in the advisor/client relationship and even more so if they re carrying debt into retirement; seniors are often embarrassed that they ve retired with debt. The same is also true for those nearing retirement and carrying debt. They suddenly realize that they re running out of time and it s starting to look hopeless. This is very stressful. They need to feel comfortable and confident enough to open-up; and that s what financial advisors (Advocis members) do. They help consumers open-up about their financial situation and then they work with them to find the best solution(s) to achieve their goals. Helping people, help themselves. It s not uncommon for there to be several meetings with no cost to the consumer while the relationship is in the early stages. There are many different advisor compensation models and that s something which is discussed upfront. The Proposed Blueprint 1. What questions and concerns do you feel must be addressed in a blueprint to help strengthen seniors financial literacy? In addition to the excellent foundation provided by the blueprint we suggest that more emphasis is needed up front, as a call to action. Potentially this would be addressed through the communication plan, but some specific aspects that come to mind are noted below: Do seniors believe that strengthening their financial literacy is worth doing? If so, are seniors / near seniors willing to take accountability in making potentially difficult decisions today in order to create a better financial future for themselves? For those who want help, how can they access the ongoing help they need which may include one-on-one opportunities with professional financial advisors? 2. Do you think the four goals identified are the right ones? Do you think there should be other goals? If so, please describe these additional goals. Goal 1: Engage more Canadians in preparing financially for their senior years Goal 2: Empower seniors to plan and manage their financial affairs Goal 3: Improve understanding of public benefits for seniors Goal 4: Increase tools to combat financial abuse of seniors Advocis agrees with the comment made at the meeting about creating stronger consistent language for the goals and believes the blue print will benefit from such an exercise. 2

3 Based on the goals as presented, we offer the following comments: Goal 2 should also focus on having the long-term care (LTC) conversation. Even those who believe they have their financial affairs in order today may not if they have a substantial unplanned LTC need. What is the potential that the senior will need long-term care? What does the senior want? What s the family s role? Who will be the care giver(s)? What happens if something happen(s) to them? Goal 3 could be positioned as a strategy or outcome of Goal 2; improving seniors understanding of public benefits is one way to empower seniors to plan for and manage their financial affairs. Although mentioned in Goal 4, consideration should be given to creating a separate goal related specifically to: Understanding the impact that diminishing capacity has on seniors ability to manage their financial affairs. Although this could lead to the LTC discussion, this goal would be more around establishing the warning signs and starting the conversation described in Goal 2, before it s too late. The focus would be on areas such as: Recognizing the warning signs The steps the senior would want taken in order to protect their financial well being when they are no longer able to do so Goal Questions Goal 1: Engage more Canadians in preparing financial for their senior years Questions 1. What barriers or disincentives discourage Canadians from preparing financially for their senior years? Lack of awareness Belief that they can t ask for financial advice because they don t have money to invest and those in debt may believe a financial advisor wouldn t help them Conflicting information, Too much information Confusing information Highly complex information; if I make this investment now, will I jeopardize something else later? This lack the confidence often results in no action. Embarrassment; belief that they should know this but they don t Ashamed; retiring in debt Overwhelmed; feeling that they ll never be able to retire, very stressed, The Government will take care of me. Perhaps knowing what that looks like today would help someone decide if that s really how they want to live in their senior years. 3

4 2. What tools or incentives can be used to help motivate more Canadians to prepare financially for their senior years? Required workplace learning Tax credits on LTC premiums for those over 50 Implementation of PRPPs Review and potential adjustment of RIF minimums in order to better financially accommodate longevity Goal 2: Empower seniors to plan and manage their financial Questions 1. As a current or future senior, can you give examples of the types of materials, tools, information, programs and services you would like to see to help you better plan and manage your money? Like me case scenarios with solutions showing when to reach out to a financial advisor. Easy access to a professional financial advisors (i.e. Advocis member) to help make it common place to see a financial advisor for a periodic financial check-up, just as people see medical doctors for their annual physicals. Financial check-ups need to be confidential and comfortable; neutral territory as trust is critical and seniors need access to the right level of affordable or free advice Possibly, a guided self-service approach where a financial advisor jumps in at an appropriate time to provide direction; just-in-time financial advice. 2. How would you like to access such resources or services? Improve access to financial advisors Most often Advisors are reaching out to clients, not the other way around. Seniors, need to be comfortable to reach out to a financial advisor for one-on-one advice The financial landscape is complex, their financial issues seem insurmountable with a common worry that they ll outlive their financial resources. While some will be comfortable sifting through all the information online, many become overwhelmed, confused and unsure if this direction is right for them and give up. Every situation is different; this is why a financial advisor can be so helpful. But it s a two-way street, those nearing retirement need to want a better financial future and be willing to do what they need to do to get there. The financial advisor can be their coach, but they have to carry the ball. 4

5 Goal 3: Improve understanding of public benefits for seniors Question What are the most effective ways (e.g., mail, advertising, Internet, in-person services) for helping you as a current or future senior understand the public pension system and the benefits you are entitled to? Required online learning tailored to common situations Information session with access to a knowledgeable advisor to answer questions Access to a one-on-one help-line in the most common languages Goal 4: Increase tools to combat financial abuse of seniors Questions 1. What specific tools would you like to have to help you ensure that you don t fall victim to financial abuse? Seniors need to know that they are dealing with an ethical, professional financial advisor. Unfortunately, anyone can hold themselves out to the public as a financial advisor or planner and currently there isn t anything a regulator or government can do about it. While provincial insurance licensing and securities registration oversees life insurance and securities transactions, the advisory conduct of financial advisors remains largely unchecked: they do not have to meet an established proficiency standard, nor subscribe to a code of professional ethics and conduct which establishes an overriding duty to consumers. This regulatory gap has resulted in serious fraud cases such as the Earl Jones case in Quebec, one of the more heavily regulated jurisdictions, and more recently the $65 million fraud case of David Michael Michaels from your home province of British Columbia. In both cases these individuals were not holding a valid license or registration during the period they committed the fraud thus avoiding regulatory oversight, and they targeted a significant number of seniors who entrusted them with their life savings. For full details on what the Advocis proposed Professions Model would mean for both financial advisors and consumers in Canada, visit 5

6 2. How can governments and others raise awareness about financial abuse? Required training for anyone interacting with seniors to identify the red flags of financial abuse and what action should be taken. When the abuse is caused by family members it may go unreported due to the real or perceived fear of repercussions. In these instances, but also in other situations as well, access to a government run whistle-blower hotline might be something to consider. Measuring Progress a. What would be good indicators in the short, medium and long-term to help us measure progress in strengthening seniors financial literacy? Increase in the number of seniors who have accessed financial education and/or information Increase in the number of seniors who have sought professional financial advice Reduction of the number of seniors retiring with debt Increase in RRSP and TFSA contributions Reduction in financial elder abuse b. How can our measurement of financial literacy keep pace with innovation in financial products and services? Through access to professional financial advisors who are required to maintain their knowledge current on an annual basis On behalf of Advocis I look forward to the opportunity to continuing to work with you on these important financial literacy issues facing all Canadians especially seniors and those nearing retirement. 6