FAIR Canada provided comments on the proposed changes to s. 14.17 of National Instrument 31-103 and the requirement to disclose non-cash incentives and embedded fees as part of the annual report on charges and other compensation. Compensation structures containing monetary and non-monetary inducements are in conflict with the interests of clients and undermine the objectivity of advisors. FAIR Canada does not think the CSA's proposals for additional disclosure of conflicts of interest will materially help protect investors. Non-cash incentives should be addressed through a broad and comprehensive approach to prohibiting conflicted remuneration. Simply disclosing the existence of non-cash incentives will not address the root cause of the problem, as disclosure is not an effective mechanism to address conflicts of interest. While potentially useful in making important information available to investors, such disclosure cannot be the main mechanism to address the investor protection concerns associated with non-cash incentives.