Susan Silma wants dealers to make total cost reporting (TCR) work for clients. Her advice is sound. The problem is that each firm will apply that advice in its own way, producing a wide variety of reports. Some will redesign from scratch. Others will adapt the rules’ own acronym-heavy sample report. Still others will layer new data onto their existing CRM2 templates. All compliant. Few, if any, easily comparable.
The two new numbers required by the rules — total dollar cost and fund expense ratio — are standardized, and consumers will be able to compare them across dealers. That is progress. But knowing what you paid is different from understanding whether you received fair value or what action to take.
The answers to those questions depend on context — how the numbers are explained, what they are compared against, how they relate to returns. The rules afford dealers wide latitude in how they present the information. Two dealers can report identical total cost figures with explanations so different that a consumer comparing them would struggle to draw any useful conclusions. The numbers are standardized. The context that makes comparison possible is not.
When the rule was introduced, regulators advertised more than arithmetic. Currently, arithmetic is largely what investors will get. The Canadian Securities Administrators said TCR would help investors “make better-informed decisions” and “enhance investor outcomes.” That requires standardization — something the industry fought hard to avoid.
It argued the changes could harm investors, demanded years of delay and succeeded in killing quarterly reporting. The end result was predictable: good intentions ground down by sustained industry resistance, delivering disclosure without standardization and transparency without actionable substance.
While, Silma’s advice cannot fix this problem, regulators can. The first reports incorporating the new requirements will be available in early 2027. Before the second round, regulators should commit to a comprehensive review — including testing of actual reports with retail investors — and publish findings and best practices in time to inform next year’s report preparation. That would not fix the original design flaw. It would, however, be a good start.