August 18, 2021

The discussion between the Approved Person and the client to ascertain the client’s investment needs and objectives should include consideration of any liquidity needs the client may have. [...] The discussion should also provide an opportunity for the client to express their investment needs and objectives in non- technical terms that are meaningful to them, such as saving for retirement to maintain a certain lifestyle, increasing wealth by a certain percentage in a specific number of years, investing for the purchase of a home, or investing for the post-secondary education of their chil. [...] We note that elsewhere in the Proposed Amendments, it is explicitly stated that registered individuals may need to assist their clients in articulating their investment needs and objectives – in our view, and considering the disconnect between investors and advisors regarding RI and ESG-focused products as discussed above, this concept directly applies to responsible investing. [...] Most notably, recent amendments to the MiFID II framework in the European Union will require that an investment firm’s obligation to act in the best interests of its clients dictate that when identifying a client or potential client’s investment objectives, relevant information includes “…the length of time for which the client wishes to hold the investment, his or her preferences regarding risk t. [...] Conclusion We submit that the idea that sustainability preferences fall within the scope of “investment objectives” is not novel, and reflects a desire by investors in Canada and across the world to invest according to their values or sustainability preferences.