The account transfer process is negatively impacted by both regulatory fragmentation and operational barriers, though the extent of the impact of each is unknown.

Regulatory considerations and operational barriers vary by product, with the latter including manual processes, legacy systems, technology gaps, prohibition of in-kind transfers and retention incentives as the key contributors to impeded or deterred transfers.

In CFFiM’s December 22, 2025 letter to Finance Canada, we provide an overview of the ‘account transfer problem’ and make recommendations on the proposed Account Switching Regulations which focus on reciprocal obligations, better accommodation of in-kind transfers, timely resolution of transfer impediments, and regulatory harmonization.