Pain of paying – the psychology of money (revisited)

I have been writing/blogging about the proposed regulatory changes regarding mutual funds and financial advisor remuneration since early 2013. Back then, regulators were telegraphing to the industry that commissions would be “targeted” for reforms. Although commissions were fully disclosed in writing, most times regulators were in favour of “direct pay” models that the UK and Australia were employing. In those countries, commissions were replaced by direct fees or bills that investors had to pay separately.

I objected to the proposal citing research about the possible “pain of paying” impacts on investors.

I recommended that we should retain what we have now - a two model system; embedded commissions and/or “direct pay” fee-based.

Years ago I bought Dr. Dan Ariely’s best seller book called “Predictably Irrational” and came across his videos on his website.

This video; inspired me to associate the “pain of paying” concept with the threat of unembedded commissions and replacing them with a “pay direct” model.

The regulator prefers to use the term “pay direct” or “direct pay” but I prefer to use the term most investors would immediately think of – “I have received a huge bill!”

This ties in very neatly with my hypothesis at the time that “pain of paying” behavioral concepts would apply directly to the possible banning of embedded commissions and that the unintentional consequences could be severe.

I have done some additional research lately because I think there is more to it than just embedded versus unembedded arguments.

Investment Counsellors often have no trouble whatsoever handing a High Net Worth (HNW) client a bill for say $10,000 a year on a million dollar account and their clients seem willing enough to pay. So if that is the case, why would mutual fund investors recoil in horror at the prospect of direct billing?

Good question.

Again Dr. Ariely’s video provided me with another clue when I bumped across some of his recent research on his “pain of paying” theory. Dr. Ariely goes on to explore an important part of the “pain of paying” equation that I had briefly touched upon in my 2013 article1 but didn’t realize how important it was at the time.

Dr. Ariely says the “pain of paying” is magnified to the nth degree by moving from a perception of free to something [painfully] quite higher.

Therefore raising a cost or price or fee of $0 to $1000 is infinitely more painful than raising costs from $1000 to $2000.

Although Investment Counsellors typically charge staggeringly high fees, why do their investors pay so willingly?

The answer is simple – those investors typically never had to deal with change. They’ve generally had to pay discreet fees right from the beginning.

I contacted Dr. Dan Ariely and asked him what the specific impacts on investors would be if investors in Canada were billed separately for their investments.

Dr. Ariely explained that if a client who has $1 million dollars invested in a savings account, for example, and pays 1% asset under management a year usually doesn’t express any concerns. However, Dr. Ariely argues that if a client had to directly pay $10,000 a year, they probably wouldn’t do it. The reason is that people may not seek advice if they have to pay for it directly.

Therefore, according to Dr. Ariely, if Canada bans embedded commissions and starts to bill investors directly, investors may refuse to pay, and if they do they will be upset. Investors may not seek advice, may stop investing or may not be put in the correct investments.

Up to this point, most references to unintended consequences refer to consequences that are relatively minor. Unfortunately, Dr. Ariely suggests otherwise.


1 Adviser fees – the pain of paying

Glenn Szlagowski is a Financial Advisor at Assante Financial Management Ltd. in Kitchener, Ontario. The opinions expressed are those of the author and not necessarily those of Assante Financial Management Ltd. This material is provided for general information and is subject to change without notice. Every effort has been made to compile this material from reliable sources however no warranty can be made as to its accuracy or completeness. Before acting on any of the above, please make sure to see a professional advisor for individual financial advice based on your personal circumstances. Commissions, trailing commissions, management fees and expenses, may all be associated with mutual fund investments. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated. Please read the Fund Facts and consult your Assante Advisor before investing.

Class “A” shares or Class “F” - which one is better?

A blog posting from an investment councillor caught my eye. The author of the article went to great lengths to denounce the fee-based mutual fund Class F share and advised his readers to avoid them. The investment counselling firm where he works has a fine reputation –catering to high net worth clients and generally, most investment councillors would favour fee-based arrangements because private investment councillors charge pretty much the same types of fees in about the same way as we do. Because his article was so unusual, I decided to look into the issues he raised.

Question: Which one is better? Class A or Class F?

Answer: It depends

Very soon, Canadian securities regulators will decide whether or not we will continue to use the current two model commission and fee-based system or whether Canada will effectively, ban all commissions like the UK and Australia for the purchase of stocks, bonds, mutual funds and other securities. Commissions have been around for centuries but depending on how things go – many commissions in Canada may soon disappear entirely. If commissions are banned, the only business model remaining is the fee-based model.

In this article we will focus on mutual fund commissions and fees, and the different types of mutual fund shares used for each. Commissions can be either embedded into the price of the mutual fund or be un-embedded and separated out like a bill. For simplicity sake, I define commissions as embedded commissions built into the price of the mutual fund. A fee however is a separate fee charged over and above the cost of the mutual fund.

Some investors prefer to pay separate negotiable annual fees usually consisting of a percentage of the value of the account. A typical fee might be 1% per year. If you wish to pay fees, investors have to buy a certain type of mutual fund share called Class “F”. Other investors prefer to pay a commission rather than a fee and have the commission built into the price of the mutual fund. This is the Class “A” fund.

In both cases, the fee or commission is fully disclosed to the investor.

Naturally, the Class “A” price will be higher than the Class “F” because the commission is already built into the price of the mutual fund. As such, you will see that the commission is built in the MER (Management Expense Ratio) of the fund. The Class “F” MER will superficially look a lot cheaper than the Class “A” fund because the separate advice fee is not included in the MER. This is because you are paying the fee separately out of your pocket or from your investment account. In reality, if the commission is the same as the fee –both Class A and Class F are equivalent (on a before-tax basis). To use an example, a mutual fund Class “A” with a MER of 2.46% is equivalent to a 1.355% Class “F” MER.

Here is how it works:

A 2.46% MER Class “A” share with a built-in 1% commission is equivalent to a 1.355% “F” Class share mutual fund that has a separate 1% fee. The difference of .105% is the extra blended GST/HST tax1 that an investor would pay on the separate 1% fee.

Some caution has to be exercised in directly comparing “A” share MERs with “F” share MERs. For comparison purposes, lower MERs are not necessarily better.

In some cases, depending on pricing, “A” shares can be a bargain. Conversely, there are instances where the “F” share is a bargain. Provincial/federal taxes or “mispricing” due to other factors may present opportunities for an advisor to explore both options with their clients. Generally though, the higher MER “A” shares should be more economic for smaller investors than “F”. And “F” shares should be more economic for large investors as fees are typically negotiable and proportionate to account size.

Back to the blog posting by the investment councillor...

In a nutshell, the author was railing against fee-based Class F shares because the negotiable fee of the Class F share in his example was greater than the fixed embedded commission of the Class A fund. Naturally, this would make the Class “F” share more expensive than the Class “A” share.

I think inadvertently, the author made the case for fixed embedded commissions rather than the alternative – separate fees. Embedded commissions are fixed by the fund company and are always disclosed to the investor prior to the purchase. However, fees on fee-based accounts are negotiable and each investor (depending on their negotiating skills) could get a fee that could be less than the fixed embedded commission or perhaps more.

So in the investment councillor’s example, why was the separate fee higher than the embedded commission? One factor is that unlike fixed embedded commissions, fees are open-ended and widely variable. For most large investment firms, fees start at 1.50% which is likely much greater than the lower fixed embedded commission. Or perhaps the issue could be that the advisor’s firm has a fee tier that is higher for smaller fee-based accounts? Or perhaps in this one instance, the investor failed to negotiate a good fee? Or maybe the advisor is a genius and charges everyone a premium fee to engage his services? That said, a low fixed commission is generally more preferable than a higher negotiable fee. A financial advisor should be able to offer you both choices and recommend the best one.

In either case, I have to disagree with the investment councillor’s conclusions. We definitely can’t say that Class F mutual fund shares are better or worse than Class A mutual fund shares. Fees are widely variable and can be an advantage or a disadvantage. Taxes can be a factor too2. It depends. Both have their proper place and have to be suitable and appropriate for each individual investor based on their personal circumstances.

1 Provincial taxes vary significantly between provinces and territories so GST/HST can vary between 5% and 15% depending on the province or territory you live in. In the example used above; a blended GST/HST tax rate of 10.5% is used.

2 Please refer to my article “After-tax considerations for fee-based accounts

Glenn Szlagowski is a Financial Advisor at Assante Financial Management Ltd. in Kitchener, Ontario. The opinions expressed are those of the author and not necessarily those of Assante Financial Management Ltd. This material is provided for general information and is subject to change without notice. Every effort has been made to compile this material from reliable sources however no warranty can be made as to its accuracy or completeness. Before acting on any of the above, please make sure to see a professional advisor for individual financial advice based on your personal circumstances. Commissions, trailing commissions, management fees and expenses, may all be associated with mutual fund investments. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated. Please read the Fund Facts and consult your Assante Advisor before investing.


After-tax considerations for fee-based accounts

There has been quite a bit of confusion regarding the effects of taxation with respect to fees and fee-based accounts containing mutual funds.

Fees that are paid by investors are subject to GST/HST and vary between the provinces anywhere between 5% and 15%. Fees paid are deductible (on your tax return) for regular open accounts, but not for RRSPs, RRIFs, TFSAs, or other registered plans.

Mutual funds generate investment income, but there are many different types of investment income and taxes can be different for each type. Interest income, Canadian dividends, foreign dividends and capital gains are all taxed differently. On an after-tax basis, fee-based non-registered accounts could have an advantage for capital gains income (versus Class “A”) but in other cases, having the commission built-in (Class “A” shares) has an advantage or is the same as a fee-based account using “F” Class shares. However, at least one other tax expert argues that even after-tax, Class “A” is exactly the same as Class “F”.

There is one other thing to consider. Fees are only deductible providing you deduct them! If you don’t go through the extra work of reporting them annually on your tax return (or have someone do that work for you), then any tax advantages regarding fee-based accounts are lost. And not knowing the new tax rules may cost you dearly. In a recent CRA tax ruling, fees that investors pay for their registered fee-based accounts, such as RRSPs and RRIFs, cannot be paid from their open, non- registered account. If you do and paid say $1,000 in fees from the wrong account, you will have to pay a CRA tax penalty of the exact same amount. To avoid tax penalties, you must ensure that your fees are deducted from their proper accounts. For example, RRSP fees are deducted from the RRSP account, while TFSA fees are deducted from the TFSA account. I suspect, investment dealers will have to fine tune their systems to accommodate these new changes.

Note: RESPs (Registered Education Savings Plans) are treated differently. Fee withdrawals from RESP plans are not permitted and fees should be paid from outside the plan.

In all cases though, it is best to consult with your own tax professional.

Jargon talk:

Non-registered account: Sometimes interchangeably referred to as an “open” account. In plain language, an open non-registered account is just a regular account that is not “registered” with the government. A chequing account is one example of an open, non-registered account.

Registered account: It is an account that is “registered” with the government. Examples of registered accounts (or plans) are RRSPs, RRIFs, TFSAs, LIRAs, LIFs, and RESPs.

CRA: Canada Revenue Agency. I like the old name better – Revenue Canada. They are the tax people.

Class “A” shares: This type of mutual fund share has embedded commissions built-in.

Class “F” shares. This is the only type of mutual fund share that is allowed to be put in a fee-based account. Since you are already paying separate fees on your account, the embedded commission is stripped out of the Class “F” MER. If this wasn’t done, you would be paying double.

MER: Management Expense Ratio: This is the annual percent it costs to run/operate the mutual fund (excluding the Trading Expense Ratio).

Glenn Szlagowski is a Financial Advisor at Assante Financial Management Ltd. in Kitchener, Ontario. The opinions expressed are those of the author and not necessarily those of Assante Financial Management Ltd. This material is provided for general information and is subject to change without notice. Every effort has been made to compile this material from reliable sources however no warranty can be made as to its accuracy or completeness. Before acting on any of the above, please make sure to see a professional advisor for individual financial advice based on your personal circumstances. Commissions, trailing commissions, management fees and expenses, may all be associated with mutual fund investments. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated. Please read the Fund Facts and consult your Assante Advisor before investing.

New mutual fund reporting - art or science?

In doing my own research on mutual fund rates of return and even gain/loss calculations, I quickly found it to be a complex subject, even for someone that has a mathematical background.  I consulted with widely respected analyst; Dan Hallett1, Morningstar Canada editor Rudy Luukko2 and Andre Fok Kam3 about some of the big changes regarding investors’ statements and reporting that we will see in 2017.

Mr. Luukko had some reservations about book values on client statements and cautions readers not to use them for their taxable gain/loss calculations. Book values (sometimes referred to as book costs) sometimes do not reflect their proper adjusted cost base used for tax calculations. Dan Hallett also questions the usefulness of book values. He says: “[Book values] may or may not reflect ACB or net amount invested.  But for most, it’s unlikely to be an accurate measure of either.”

Here is another scenario where a book value may not reflect a true gain/loss. Because book values increase with each reinvested distribution, for some fixed income mutual funds that reinvest large distributions on a regular basis, you could theoretically encounter a situation where the book value exceeds the market value. Mathematically, this would show as a loss when in fact, the mutual fund could have a gain.

Why is ACB (Adjusted Cost base) so important? Tax professionals would use ACB to determine capital gain/loss for tax purposes. What about book values? Mr. Luukko says the intent of using book values was to comply with new regulatory requirements (CRM2) as securities dealers are mandated to provide gain/loss information to investors.

Dan Hallett has written an excellent article (with examples) on the new but very different way of calculating a rate of return called dollar or money weighted rate of return. A link is provided at the end of this article. Investors will be seeing these different performance numbers in a brand new Investor Performance Report that will be mailed out in 2017. In his article, Mr. Hallett cautions readers to be careful with these reported performance numbers, noting that calendar date biases may result in numbers that may not be meaningful in certain circumstances or comparing rates of return with other advisors may be difficult.

Securities regulators have decided that money weighted/dollar weighted return is to be used from now on. This formula is also referred to as the IRR (Internal Rate of Return). The return of the mutual fund itself uses a different formula called a time weighted rate of return.

Although the regulators have decided that advisors and their firms must use money weighted rate of return calculations, Mr. Hallett says he would have preferred to see time weighted calculations as did the CFA Institute“Time weighted would have made so many things much easier – e.g., comparisons with broadly based indices; custom benchmarking; calculation of other performance metrics like Sharpe, alpha, etc.”

While regulators allow the advisor firms to use any method for internal reporting purposes, the money weighted return method must appear on the new Investor Performance Report that investors will be receiving in the mail in 2017. Some Dealers will be giving their advisors the option of adding time-weighted returns to advisor generated rate of return reports so investors can see both money weighted and time weighted rates of returns.

However, investors should be aware of some of the disadvantages of using money weighted (IRR) rate of return calculations. For instance, the formula presumes all cash flows during the time frame measured, are reinvested at the same internal rate of return – an assumption that some believe is completely unrealistic. Although empirically, the IRR is only the number or numbers that makes the Net Present Value of the cash flows = 0 in the IRR equation. If there are multiple rates of return that satisfies the equation, then that’s just the math. Having said that, in speaking with a mathematician - a Ph.D. in Applied Mathematics, there could also be a correlation between cash flow size and the possibility of multiple returns as well. He cautioned about “black box” formulas that do not handle IRR calculations very well and had some cautions about the use of Excel for IRR calculations.

Much of the modern literature seems focused on “fixing the IRR problem” by approximating the IRR formula using other equations. Ironically, the newly mandated use of IRR replaces the previous preferred rate of return model called the Modified Dietz Method which doesn’t have the multiple rate of return problem.

In the paper5 from Yuri Shestopaloff, Ph.D. and Wolfgang Marty, Ph.D. (Properties of IRR Equation with Regard to Ambiguity of Calculating of Rate of Return and a Maximum Number of Solutions) the authors appear to prefer the Modified Dietz Method for the calculation of rates of return.

If there are a number of swings of money coming in and going out of a mutual fund account, calculating an IRR rate may result in two or more multiple rates of return4. Or even worse –none.  Mathematically speaking, each of these multiple returns are 100% correct and the observer is sometimes left with the difficult task of choosing one over the other. Sometimes it may not be intuitive which one is the “more correct” answer.

[Editor’s note: Although mathematicians can appreciate the beauty of pure math and report there can be more than one correct answer for the same polynomial equation (Descartes Rule), telling investors they could have multiple rates of return for the same mutual fund –all of which are perfectly correct –will make for some engaging discussions.]

Dan Hallett says that many clients have money moving in or out of their accounts and Descartes Rule can be a real issue for them.

Although going forward, calculating money weighted (IRR) rates of return (despite the challenges) could be for the most part, useful, there is a red flag regarding the transfer of mutual funds from one dealer to another. Mr. Hallett is referring to a dealer change when an advisor moves from one dealer to another. This is a very common scenario. In this case, the client’s mutual funds are transferred intact [this is called an in-kind transfer] from the relinquishing dealer to the new dealer at the market price the day the units are received by the new dealer. For the purpose of calculating a money-weighted rate of return (IRR), the original purchase cost(s) of the mutual fund do not move to the new dealer so the transfer-in of securities is posted at market value. If it is counted as a very large new purchase it could skew the IRR and it is debatable whether the rate of return would be meaningful. This will likely affect the “since inception” rate of return if you opened your existing account with an in-kind securities transfer. If the time frame measured excludes the securities transfer, all the other rates of return (except the “since inception” return) i.e. 1 year, 3 yr, 5yr or 10 yr returns should be OK.

Difficulties may also arise if a mutual fund is consolidated or merged with another mutual fund resulting in a large in-kind “purchase”. Again, this has the potential to skew returns. Your advisor is best equipped to discuss or alert you about these special situations.

However, Dan Hallett emphasized if the in-kind transfer is “new money” - say from another firm or another adviser, then it can be used as a basis for rate of return calculations.

Andre Fok Kam on the other hand, has a different viewpoint with respect to in-kind transfers of securities. According to Mr. Kam, an in-kind securities transfer is treated the same way as a new cash purchase of a mutual fund and under the letter of the law, the percentage rate of return generated would be perfectly valid under the new CRM2 securities rules.

Notwithstanding the potential issue of multiple rates of returns, if you never have an in-kind transfer in your account and opened your account with a cash purchase rather than a securities transfer, then all of your returns –including since inception should be OK.

Although convention would hold that the best way to measure performance is to compare original costs with a market value – transaction histories are not transferred when a client changes advisors or advisors changes firms. As a result, original costs are left behind. Although attempts have been made in the past to use book values(which incorporates original costs) for rate of return calculations, book values are incremented up every time you re-invest a distribution (so you aren’t taxed twice) in a taxable account. As a result, some say that book values should not be used for performance rate of return calculations at all.

Confusing? It can be. When you receive your new Investor Performance Report, bring it in to your Financial Advisor so both of you can review and discuss it in more detail.


1 Dan Hallett is Vice-President & Principal of Oakville, Ontario-based HighView Financial Group. Dan's views and opinions are regularly featured in the media and have appeared in several best-selling personal finance and investment books. He is a regular contributor to the Globe & Mail and many other business publications.

2 Rudy Luukko is editor, investment and personal finance, at Morningstar Canada. A former chair and founding member of the Canadian Investment Funds Standards Committee (CIFSC), he has also co-authored courses for the Canadian Securities Institute.

3André Fok Kam, CPA, CA, MBA is a consultant to the securities industry. He has advised regulators, fund managers, advisors and dealers.He has served on the Board of Directors of several fund managers, portfolio advisers and dealers and has served as Investment Director and CCO. He writes extensively for several trade publications.

4Descartes Rule: There is an indirect relationship between Descartes rule and the number of sign changes between positive and negative cash flows in or out of a portfolio ( money moving in and money moving out), then mathematically, there is a possibility of multiple rates of returns generated by the money weighted rate of return (IRR) formula. Search term: Descartes Rule of Signs.

5 Yuri Shestopaloff, Ph.D.,Wolfgang Marty, Ph.D. Properties of IRR Equation with Regard to Ambiguity of Calculating of Rate of Return and a Maximum Number of Solutions

Dan Hallett: Making sense of your new CRM2 performance report:

Rudy Luukko: CRM2 won't solve tax-reporting headaches


Estate Planning: What to do when a power of attorney has no power

Written by Glenn Szlagowski- Financial Advisor and Cheryl Butler, CFP, Financial Planning Advisor

What is a Power of Attorney?

According to the Government of Canada1, “a power of attorney is a legal document that you sign to give one person, or more than one person, the authority to manage your money and property on your behalf. In most of Canada, the person you appoint is called an “attorney”.

We often hear claims that powers of attorney (POA) can do or sign anything on behalf of another person. That statement is not quite accurate. It is very important to note that a POA may have finite powers that may not be equivalent to that of the grantor. For instance, a POA cannot designate a beneficiary or change an existing beneficiary for a registered plan. This could have significant tax or legal consequences if the POA is attempting to set up a new registered plan (e.g. RRSP, RRIF, TFSA, etc.).

In the absence of a beneficiary or successor annuitant, the beneficiary, by default, would be the grantor’s Estate where it could be subject to provincial probate fees. If, for example, you use a TFSA, in the case of death, the TFSA is collapsed and goes to the Estate. Probate fees will have to be paid, and the surviving spouse will not be able to put the money into their own TFSA except for the relatively small (currently $5,500) annual TFSA contribution limit.

However, if there is an existing account and you will be exercising a POA, it is best to ask the institution holding your registered plan whether the beneficiary designation is attached to the plan/account or to individual investments. If it is attached to the plan/account, then you may be in luck. It may be possible to transfer-in TFSAs from other financial institutions, or even make new contributions in the case of TFSAs or RRSPs, using a POA while utilizing the existing beneficiary designation.

Do you have accounts or investments issued by a bank or credit union domiciled in another province in Canada? If so, there are some potential landmines that can be an unpleasant surprise. For instance, if you have a POA that was created outside the province of British Columbia, and you wanted to exercise that POA, you may run afoul of an arcane piece of provincial legislation. For example, if you need to exercise an out-of-province POA to transfer an RRSP, RRIF, or TFSA, you will be required to supply the financial institution in British Columbia with a “Certificate of Extrajurisdictional Solicitor”2. Your lawyer must complete and certify this document each time you need to exercise a legal POA in British Columbia. This process takes time and lawyers at $400.00 per hour are not inexpensive.

Now, we can’t put all the blame on British Columbia. There is a credit union in Saskatchewan that will also not transfer a registered plan using a POA without a lawyer’s re-certification of the original POA document. Even here in Ontario, many financial institutions refuse to recognize a general POA and will not accept its instructions. Although your financial adviser will go to bat for you, in some extreme cases, your lawyer may have to apply legal pressure to enforce a valid POA document.

You can avoid many of these issues by opening up a nominee account at a securities dealer. In using this type of account, it’s the nominee “container” that has the beneficiary designation. Even if you have to change the investments, the beneficiary always stays the same. In other words, the beneficiary designation is attached to the container holding the investments, not to the individual investments in the container.

Just as it is important to buy life insurance before you die, it is equally important to structure your financial affairs for estate planning purposes before an accident or a physical or mental health decline renders you incapable.

Need help with setting up your banking and client name GIC accounts for estate planning purposes? Please contact me at (519) 744-3020 or at for more information.





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