One all-in rate for your account
The report shows fund costs in dollars and a percentage for each fund. It doesn't combine your advisory fee and fund costs into one rate for the whole account, the number most useful for comparison.
“What is my total all-in cost as a percentage of my portfolio, including fees inside my funds?”
Private and pooled funds sold without a prospectus
Regulators excluded prospectus-exempt funds because of implementation issues and said they may extend the rules later. Larger portfolios often hold pooled or private funds, and their costs won't be added up for you. You'll only get a general notice that such products have embedded fees.
“Are any of my holdings prospectus-exempt or pooled funds? What do they cost each year, all-in?”
Corporate, holding-company and trust accounts over $10 million
Under CIRO rules, the annual fee report is required for retail clients. A corporation, trust or other non-individual with more than $10 million in securities at a dealer can be classified as an institutional client, so these accounts may not receive the report at all.
“How is my corporate account classified? Will it receive the annual cost report?”
Currency conversion spreads
Regulators don't treat foreign exchange spreads as a transaction charge, so they aren't reported. Firms are only encouraged to include a general notice. With large US-dollar holdings, the spread on every conversion adds up.
“What spread do you charge on currency conversions, and roughly how much did I pay last year?”
Structured notes
Principal-protected and market-linked notes are outside the rules. Their embedded costs aren't quantified, only noted in general terms.
“What fees and dealer compensation are built into the notes I hold?”
Bond mark-ups
When a dealer buys or sells bonds for you, it can report its mark-ups in dollars, or report only commissions plus a general statement that remuneration was added to the price. A bond-heavy portfolio may never see a dollar figure.
“Do you report my bond mark-ups in dollars? What did I pay on bond trades last year?”
Third-party fees
Custody, trustee and intermediary fees or interest paid to third parties aren't included in the totals. The report only has to say they may not be reported.
“Am I paying any custody, trustee or interest charges outside your fee?”
A benchmark for your returns
Your annual performance report doesn't have to compare your returns with a benchmark. You'll see what you paid, but not necessarily whether it bought better results.
“What benchmark should my portfolio be measured against, and how have I done after all fees?”
Start with your all-in rate
The one number the new report leaves out.
Sources
- CSA & CCIR Notice of Publication: Total Cost Reporting, April 20, 2023
- CIRO Bulletin 24-0288: Enhanced Cost Reporting, October 10, 2024
- CIRO Investment Dealer and Partially Consolidated Rules (Rules 1201, 3811)
- Companion Policy 31-103CP (foreign exchange spreads guidance)
- Nova Scotia Securities Commission: CRM2 annual performance report
