| 5-913177 | |
| 24(1) | P. Spice |
| (613) 957-8953 |
Attention: 19(1)
February 5, 1992
Dear Sirs:
Re: Registered Retirement Savings Plan ("RRSP") Marketing Plan
We are writing in reply to your letter of October 25, 1991, which was forwarded to us by the Department of Finance. You had asked for an official ruling from the Office of the Superintendent of Financial Institutions concerning the marketing plan which you describe in your letter.
We are unable to provide an official ruling unless your request is submitted in the form and manner required in Information Circular 70-6R2 dated September 28, 1990 as issued by Revenue Canada Taxation. We can provide, however, some general comments concerning the Income Tax Act rules respecting incentives offered by RRSP issuers.
Offers from RRSP issuers of such things as chances to win prizes, trips, free appliances, and interest-free loans to purchasers of their RRSP's are advantages that are prohibited by paragraph 146(2)(c.4) of the Income Tax Act notwithstanding that the customer could obtain the advantage by some other means such as purchasing a non-registered investment. If the advantage remains in the RRSP, such as the earning of bonus interest in the plan or a contribution of property into the RRSP, this would not contravene the aforementioned provision.
Although these comments are not binding on the Department, we trust they are helpful.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate