110106IS-IIROC-Suitability-revisions-comment-letter Final

January 7, 2010 Brendan Hart Policy Counsel, Member Regulation Policy Investment Industry Regulatory Organization of Canada Suite 1600, 121 King Street West Toronto, Ontario M5H 3T9 bhart@iiroc.ca Manager of Market Regulation Ontario Securities Commission 20 Queen Street West 19th Floor, Box 55 Toronto, Ontario M5H 3S8 marketregulation@osc.gov.on.ca Dear Sir and Madam, RE: Request for Comment Plain language rule re-write project - Dealing with clients, Proposed Rules 3400-3900 1. Background 1.1. We are pleased to provide you with the comments of the Canadian Foundation for Advancement of Investor Rights (“FAIR Canada”), in response to the Request for Comments (the “RFC”) by the Investment Industry Regulatory Organization of Canada (“IIROC”) on the Plain Language Rule Re-write project Dealing with Clients, Proposed Rules 3400-3900 (the “Proposed Rules”). 1.2. FAIR Canada is a national, non-profit organization that advocates for stronger investor protections in securities regulation. Visit www.faircanada.ca for more information. th161 Bay Street, 27 Floor | Toronto, ON | M5J 2S1 | 416-572-2039 | www.faircanada.ca 2. General Comments on the Proposed Revisions 2.1. Broadly, we agree with the Proposed Rules. Our comments will focus on the rewritten Proposed Rule 3400, Suitability as well as its relevant Guidance Note 3400-1 Recommendations (the “Suitability Rules”). This letter will begin with our comments on ...