Submissions archive

December 16, 2020

PMAC Submission on OSC Statement of Priorities for Financial Year to End 2022

OVERVIEW PMAC is supportive of the four overarching goals set out in the Statement of Priorities and we are pleased to have the opportunity to provide the following feedback on certain aspects of them. We have made several recent submissions … Continue reading

December 7, 2020

PMAC submission on Quebec Bill 64

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). PMAC’s member firms believe that privacy legislation needs to be modernized and streamlined in … Continue reading

November 13, 2020

PMAC Submission to FSRA on FP/FA title regulation

Background The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the request for comment from the Financial Services Regulatory Authority of Ontario (FSRA) on Proposed Rule … Continue reading

October 23, 2020

PMAC Submission on CSA Consultation Paper 25-402 Consultation on the Self-Regulatory Organization Framework

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Canadian Securities Administrators (CSA) on CSA Consultation Paper 25-402 Consultation on the Self-Regulatory Organization Framework (the Consultation). PMAC represents over … Continue reading

October 20, 2020

PMAC Submission on CFA Institute ESG Standards Consultation

OVERVIEW The Portfolio Management Association of Canada (PMAC), through a working group consisting of CFAs and ESG experts and through its wider Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding the … Continue reading

September 22, 2020

PMAC Submission on Shared CCO Models

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding CSA Staff Notice 31-358 – Guidance on Registration Requirements for Chief Compliance Officers … Continue reading

September 4, 2020

Consultation — Modernizing Ontario’s Capital Markets

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Capital Markets Modernization Taskforce (CMMT) for your consideration, further to our meeting with the CMMT on May 11th and the publication … Continue reading

August 14, 2020

Financial Industry Request for Transition Period with respect to penalties

On behalf of the CBA, IIAC, IFIC, and PMAC, we want to acknowledge and thank you for the collaboration and assistance the CRA and the federal government has provided the financial services industry with respect to the “Guidance on the … Continue reading

July 16, 2020

CSA Notice and Request for Comment – Proposed Amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations and Companion Policy to Enhance Protection of Older and Vulnerable Clients

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding CSA Notice and Request for Comment – Proposed Amendments to National Instrument 31-103 … Continue reading

July 3, 2020

PMAC Submission on Proposed OSC Rule 81-502 – Restrictions on the Use of the Deferred Sales Charge Option for Mutual Funds

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding OSC Notice and Request for Comment – Proposed Ontario Securities Commission Rule 81-502 Restrictions on the Use of the Deferred … Continue reading

May 1, 2020

PMAC Submission to Department of Finance Canada – Challenges Posed by COVID-19 to Federally-regulated Pension Plans

Background The Portfolio Management Association of Canada (PMAC) wrote to comment on an issue of impact to member firms and intensified by market conditions arising from by the COVID-19 pandemic. PMAC represents over 280 asset management firms, collectively managing over … Continue reading

March 5, 2020

PMAC Submission on CSA Consultation Paper 51-405 – Consideration of an Access Equals Delivery Model for Non-Investment Fund Reporting Issuers

Background The Portfolio Management Association of Canada (PMAC) was pleased to have the opportunity to submit the following comments regarding CSA Consultation Paper 51-405 – Consideration of an Access Equals Delivery Model for Non-Investment Fund Reporting Issuers (the Consultation). PMAC … Continue reading

February 27, 2020

PMAC Submission on Manitoba Bill 8 – The Pension Benefits Amendment Act

Overview The pension committee of the Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide member feedback in respect of Bill 8 – the Pension Benefits Amendment Act (Bill 8). PMAC is pleased to see … Continue reading

February 19, 2020

Submission on Department of Finance Pre-budget Consultations

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, provided comments to the Department of Finance Canada (Finance) regarding Pre-budget Consultations 2020 (the Consultation). PMAC represents 280 investment management firms that collectively manage over … Continue reading