416.368.0700 anne@annefreed.com

Financial Disclosure in Negotiating Separation Agreements: Why is it Necessary?

For those who are embarking on separation or divorce, a key element of reaching a fair Separation Agreement, is the exchange of financial disclosure between the parties. When I mediate my cases, I often work with the parties to facilitate this disclosure, which assists in cost efficiency.

CLIENT TO HERSELF: “Why is my lawyer making me prepare financial disclosure when all I need is a separation agreement?”

CLIENT TO LAWYER: “I know what my husband has and he knows what I have. We’ve agreed on how we’re dividing the assets.  Just draft it up so we have a legal separation agreement!”

These are comments often made by clients who have retained lawyers to assist them in negotiating a Separation Agreement.  Reasons include:

  • I (the client) don’t have the time or patience to do this work;
  • I don’t want to pay for my lawyer’s time in doing this;
  • This is just a make-work project by the lawyers (after all that’s why they’re all rich, isn’t it!); and
  • I trust my spouse!

So why is financial disclosure in negotiating separation agreements (and marriage contracts also!), necessary?

The following are the answers:

The necessity of Informed Consent: One of my clients, who works in the medical field, analogizes this requirement to the written consent – “informed consent” – that a patient must give that he/she has been told of the possible risks before consenting to a surgery. For example, before undergoing eye surgery, the patient must be told of and understand the possible risks of going blind in the surgery. Using this analogy, how can a husband and wife agree on how the assets and debts will be divided or distributed it they don’t know what all the assets and debts are, or their values?

The Terms of Agreements change once people are informed: As an example, I had a mediation case where, when I met each spouse separately at the outset as is my process when doing mediation, I ascertained that the husband had a pension of many years with his employer. When I met the wife she told me that “This will be the easiest open and shut mediation you have ever done!” When I said “You know he has a pension and you know that is considered an asset under our Ontario law” she said “Yes, but I don’t want any part of it, I don’t care what it’s worth” and that her husband would have a fit if she asked for a share. I then asked her “What if I request an actuarial valuation of his pension – 2 – and it turns out it’s worth 1 million dollars?” Knowing that she could be entitled ( in the absence of any other assets) to half of that value, my client wisely told me to go ahead and have the pension valued. In fact the final point they ended up arguing about, prior to settling all terms of their Separation Agreement, was the pension value. The actuary provided 3 possible values based on 3 possible retirement ages of the husband, and guess which value each spouse argued!

Ignorance is not bliss when it comes to negotiating a Separation Agreement or a Marriage Contract! It’s easy to agree on things, e.g. “I don’t want his pension,” if one doesn’t know what they’re worth; or that “Each shall keep his/her own assets,” without knowing what they’re worth. In order to make an agreement that will stand the test of time, it must be based on the exchange of clear, thorough and complete financial disclosure, so that each party, when negotiating the terms of the agreement, will make their decisions based on knowledge and facts, i.e. informed consent.

Click here to read the rest of my article (first written in 2013 and still relevant and important today).

Until next time!

Anne!

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A “QUICK AND DIRTY” SEPARATION AGREEMENT: IS IT ENOUGH?

Dear Readers,

Many people come to Family Lawyers asking for a quick and dirty (and cheap!) Separation Agreement. Today’s question is: will such an Agreement be fair to the parties and will it stand the test of time?

I had a client – Mrs. X – who came to me several months after she had signed a (‘quick and dirty’) Separation Agreement with another lawyer. Mrs. X deeply regretted the Agreement she had signed and felt that she had settled for far less than she should have. She told me that she had separated the past fall and had signed the Separation Agreement soon after. Further questioning revealed that – in the interests of getting her Separation Agreement finalized quickly – she had asked her lawyer to take several shortcuts. These shortcuts included: not obtaining a value of the matrimonial home, not requesting a valuation of her spouse’s pension, not requiring Mr. X to provide the required full and detailed financial disclosure, and so on.

It was clear that Mrs. X had not been provided all of the detailed documents necessary so that her lawyer could do the necessary analyses to calculate Mrs. X’s legal entitlements.

It was also clear that Mrs. X had been very worried about legal fees, and hence had limited her previous lawyer’s time/work.

Now, six months later, what was Mrs. X to do? The good news is that – in family matters – a spouse can apply to the Court to set aside a Separation Agreement. However, this is an uphill battle, and the onus will be on Mrs. X to prove the necessary circumstances/elements that the law requires in order to win such an application to the Court.

The difficult part is – in addition to the fact that in Court there are no guarantees of victory – the work that Mrs. X’s new lawyer will have to do will greatly add to her legal fees, as the work will be much more complicated than had Mrs. X allowed her previous lawyer to do the necessary work in the first place.

So, today’s teaching piece is that, if you’ve decided to separate, beware of doing a “quick and dirty” Separation Agreement. While you may succeed in your goal of saving time and legal fees in the immediate present, the risk is that, in doing so, you will have likely limited your lawyer’s time and work to do her due diligence necessary to meet the long-term results you want, i.e. a Separation Agreement that is fair to you, and also that will stand the test of time.

Until next time.

Anne

Anne Freed holds a BA (Honours Sociology), JD (Juris Doctor, Law Degree), Master of Laws Degree (LL.M.) in Alternative Dispute Resolution (ADR), Advanced Training in Mediation, Arbitration and Collaborative Practice, Certification in Collaborative Practice, as well as over 38 years’ experience in the practice of Family Law, Mediation and Arbitration. Anne is also a Certified Specialist in Family Mediation (FDRP Med) and OAFM Accredited Family Mediator (AccFM).

© Anne E. Freed, November 2025

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