Submissions archive

December 17, 2021

PMAC Comment Letter – OSC Statement of Priorities For Financial Year to End 2023

Overview PMAC is supportive of the four overarching goals set out in the Statement of Priorities. We are pleased to have the opportunity to provide the following feedback on certain aspects of them. Read the full submission here.

December 15, 2021

PMAC Submission – FSRA Financial Planner and Financial Advisor Rule and Guidance

Background As noted in our July 5th submission to FSRA, PMAC believes that the proposed regulation of the Financial Planner (FP) title presents an opportunity to achieve two important goals: (i) level the playing field for those providing financial planning … Continue reading

December 10, 2021

PMAC Submission – AMF Consultation on Regulation respecting complaint processing and dispute resolution in the financial sector

PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that elevate standards in the industry and improve investor protection. PMs generally manage client assets on a discretionary basis; they are subject to the highest proficiency standards in … Continue reading

October 25, 2021

PMAC Submission – New Brunswick Financial Planner and Financial Advisor Rule

Overview The Portfolio Management Association of Canada1 (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the Financial and Consumer Services Commission of New Brunswick (FCNB)’s consultation notice – Title Protection 2021 … Continue reading

October 4, 2021

PMAC Comment – CSA Position Paper 25-404 New 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 Position Paper 25-404 – New Self-Regulatory Organization Framework (the Position Paper). PMAC represents over … Continue reading

October 1, 2021

PMAC Submission on Saskatchewan Financial Planners and Financial Advisors Regulations

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 and Consumer Affairs Authority of Saskatchewan (FCAA) on Proposed Regulations … Continue reading

September 29, 2021

PMAC Response to the CFA Institute’s Diversity, Equity and Inclusion Code

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors and individuals alike. Read PMAC’s the full response to the CFA Institute’s Diversity, Equity and Inclusion (DE&I) Code here … Continue reading

September 7, 2021

PMAC Submission on Ontario Privacy Consultation

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 has been supportive of proposals that provide assurances to individuals that their privacy … Continue reading

August 26, 2021

PMAC submissions to Canada Revenue Agency (CRA) on draft revised Guidance for FATCA and CRS

PMAC responded to the CRA’s consultation draft revised guidance with respect to FATCA and CRS. Read the submission on CRS here and on FATCA here.

August 16, 2021

PMAC Submission – IOSCO Consultation Report: Recommendations for Sustainability-Related Practices, Policies, Procedures and Disclosures in Asset Management

Overview The Portfolio Management Association of Canada (PMAC), with the assistance of a member working group consisting of CFAs and ESG experts, is pleased to have the opportunity to submit the following comments regarding the International Organization of Securities Commissions … Continue reading

August 4, 2021

PMAC Submission – Special Committee to Review the Personal Information Protection Act

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to respond to British Columbia’s (BC) request for comments on modernizing the Personal Information Protection Act (Consultation). PMAC is supportive of BC’s efforts to enhance British Columbians’ individual … Continue reading

August 4, 2021

PMAC Submission on Relief to Foreign Financial Service Providers

Overview The Portfolio Management Association of Canada (PMAC), through its International Committee, is pleased to have the opportunity to respond to the request for comment regarding the Relief to Foreign Financial Service Providers Consultation Paper (the Consultation) issued by the … Continue reading

July 27, 2021

PMAC Comments on Proposed British Columbia Instrument 51-519 Promotional Activity Disclosure Requirements.

Overview PMAC agrees that any form of market manipulation or investor deception must be deterred and appropriately punished. We are generally of the view that regulation should be focused on specific behaviours and desired outcomes. We believe that the Consultation … Continue reading

July 15, 2021

PMAC Submission – Exposure Draft – CFA Institute ESG Disclosure Standards for Investment Products

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

July 5, 2021

PMAC Submission on FSRA Financial Planner and Financial Advisor Rule and Guidance 2021

Overview 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) regarding its updated … Continue reading

June 11, 2021

PMAC Comment on Saskatchewan FCAA Pension Solvency Funding Review

Overview PMAC is supportive of the FCAA’s goal of seeking stakeholder feedback on options to amend the solvency funding framework for single employer private sector pension plans (SEPPPs) under The Pension Benefits Act, 1992 (Act) and the Pension Benefits Regulations, … Continue reading

May 5, 2021

PMAC Submission – CSA on Proposed Amendments to NI 33-109 – modernizing registration information requirements, clarifying outside activity reporting and updating filing deadlines

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to respond to CSA Notice and Request for Comment on Proposed Amendments to National Instrument 33-109 – Registration Information (NI 33-109) and Changes to Companion Policy … Continue reading

March 18, 2021

PMAC Submission – CSA Consultation Paper 25-403 – Activist Short Selling

OVERVIEW PMAC generally favours principles-based regulation that recognizes differences in business models, sizes, and client types. We support the CSA’s decision to consult with stakeholders on the important issues raised in the Consultation. Given the fast pace of change in … Continue reading

March 12, 2021

PMAC Comment on Bill C-11, Digital Charter Implementation Act 2020

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). Portfolio managers have a fiduciary duty to act with care, honestly and in good … Continue reading

March 1, 2021

PMAC submission on the OSC Exemptive relief for international firms under CFA and Securities Act

Re: OSC Notice and Request for Comment – Proposed OSC Rule 32-506 (Under the Commodity Futures Act) Exemptions for International Dealers, Advisers and Sub-Advisers and Proposed amendment to OSC Rule 91-502 Trades in Recognized Options under the Securities Act The … Continue reading

February 23, 2021

PMAC Submission on the Ontario 2021 Budget Consultations

The Portfolio Management Association of Canada (PMAC) appreciates the opportunity to comment on the 2021 budget, with a focus on the recommendations of the Capital Markets Modernization Taskforce (Taskforce). We urge Ontario to continue to support the Cooperative Capital Markets … Continue reading

January 14, 2021

PMAC Submission on Federally Regulated Private Pension Plans

Re: Strengthening Canadians’ Retirement Security – Proposals to Support the Sustainability of and Strengthen the Framework for Federally Regulated Private Pension Plans OVERVIEW The Portfolio Management Association of Canada (PMAC), through its pensions advocacy committee, is pleased to have the … Continue reading