Association urges the securities regulator to adopt multi-year fee frameworks and explore AI efficiencies before raising costs on registered firms and advisors
The Securities and Investment Management Association (SIMA) is urging the British Columbia Securities Commission (BCSC) to anchor fee-setting in transparency, predictability, and fiscal discipline.
The association warns that a proposed $8 million annual fee revenue increase adds to an already heavy cumulative regulatory cost burden on Canadian firms.
In a submission this week, SIMA welcomed the BCSC's periodic fee review as a sign of the regulator's commitment to sustainability but outlined significant concerns about the scope and rationale of the proposed increases.
Cumulative burden raising alarm
SIMA's core concern is that advisors and firms are simultaneously absorbing fee changes from multiple directions such as CSA system fee hikes, major regulatory initiatives such as Total Cost Reporting, and now a BCSC review, all within a compressed timeframe.
The association argues that each increase may appear reasonable in isolation, but the cumulative impact on multi-provincial registrants is substantial.
Andy Mitchell, President and CEO of SIMA, said the solution lies in better planning frameworks rather than repeated fee hikes.
"Regulatory fees should be set within a multi-year framework with accurate cost forecasting so firms can plan, invest, and innovate with confidence," he said.
AI and automation questioned over fee hike on filings
One of SIMA's more pointed submissions targets the proposed 50% increase in exempt distribution report filing fees (from $200 to $300), which would mark the second major overhaul of that fee in three years. The association argues that instead of raising fees, the BCSC should explore whether artificial intelligence and automation could streamline what it describes as "highly prescribed reports" that are "ripe for automation and AI-driven efficiencies."
SIMA is asking the commission to re-examine whether an AI-driven approach could achieve the same administrative outcomes without the cost increase; a question with implications well beyond British Columbia, given the growing industry focus on technology-enabled regulatory compliance.
Three principles for responsible fee-setting
SIMA's submission calls on the BCSC to adopt three guiding principles for any fee-setting process:
Transparency in cost recovery means firms need clear sight into how fees are calculated, including how deficits and surpluses are managed and how the projected $8 million increase would be distributed across registrant categories, issuers, and filing types.
Predictability through multi-year frameworks would allow investment managers and financial planning firms to budget for regulatory costs with confidence, rather than responding to periodic and unexpected adjustments.
Discipline in addressing existing surpluses means the BCSC should demonstrate it has exhausted internal efficiencies and drawn down any reserve funds before seeking additional revenue from registrants.
National harmonisation a priority
SIMA also used the submission to renew its call for greater fee consistency across Canadian jurisdictions.
The association recommends that regulators designate lead jurisdictions for specific regulatory initiatives, such as crypto asset reviews, to reduce the duplication of compliance costs that currently weighs on firms operating across multiple provinces.
Inconsistent fee structures across provincial regulators increase administrative complexity and add indirect costs that can ultimately filter through to clients.
SIMA's submission signals a broader industry sentiment: as regulatory activity intensifies and technology reshapes the financial advice landscape, the sector expects regulators to apply the same rigour to their own cost management that they demand of the firms they oversee.
The BCSC fee review is ongoing. SIMA's full submission is available on the association's website.
