Submissions archive

September 13, 2022

PMAC Comment Letter to CSA on National Instrument 43-101 Consultation

Important Context and Background PMAC’s members are fiduciaries entrusted to manage their clients’ assets in the clients’ best interests. As asset managers, our members are supportive of processes that increase transparency and that provide readily comparable information to assist them … Continue reading

August 31, 2022

PMAC Comment Letter to CAPSA on Guideline No. 3

Key Recommendations Provide additional information on the policy reasons for the updates to the Guideline, clarification of certain changes, and harmonize terminology with securities legislation. Create a separate Guideline for the decumulation aspects with additional guidance. Continue or expand existing … Continue reading

July 28, 2022

PMAC Comment Letter to CSA-CCIR Total Cost Reporting Joint Consultation

Key Recommendations Provide investors with total cost information. We believe that investors want to know three key pieces of information: (1) what their investments are worth today; (2) how much their value increased (or decreased) over time; and (3) how … Continue reading

June 28, 2022

PMAC Comment Letter to CSA on Application for Recognition of New SRO

Key Recommendation With respect to the Application for recognition of the New SRO, and Draft By-Law No. 1 in particular, we are generally pleased with the proposed governance and oversight reforms. It is clear that the CSA took stakeholder feedback … Continue reading

April 28, 2022

PMAC Comment Letter – Modernization of the Prospectus Filing Model for Investment Funds

Overview The Portfolio Management Association of Canada (PMAC), is pleased to have the opportunity to submit the following comments regarding the CSA Notice and Request for Comment – Proposed Amendments to National Instrument 41-101 General Prospectus Requirements, National Instrument 81-101 … Continue reading

April 20, 2022

PMAC Comment Letter on 2022 OSC Fees Consultation

Overview The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding Proposed Amendments to OSC Rule 13-502 Fees, OSC Rule 13-503 (Commodity Futures Act) Fees and Proposed Changes to their Companion … Continue reading

April 5, 2022

PMAC Submission to Department of Finance on draft tax proposals

Trust reporting requirement exemption should include pooled funds The lack of MFT status for pooled funds results in several unfair consequences compared to mutual funds and segregated funds. This inequity includes the impacts of the proposed trust beneficial ownership reporting … Continue reading

March 21, 2022

PMAC Submission to CSA on 2022 Derivatives Business Conduct Consultation

OVERVIEW The Portfolio Management Association of Canada (PMAC), through our Industry Regulation & Taxation Committee, is pleased to have the opportunity to submit the following comments regarding the CSA’s Notice and Third Request for Comment – Proposed National Instrument 93-101 … Continue reading

February 28, 2022

PMAC submission on Federal Pre-Budget Consultations 2022

  The Portfolio Management Association of Canada (PMAC) represents over 300 investment management firm members that collectively manage $3 trillion in assets for pension plans, endowments, individual and group RSPs, and other investments across Canada. We are writing to ask … Continue reading

February 18, 2022

PMAC Comments on the Ontario Capital Markets Act Consultation Draft

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry of Finance (Ministry) on the Capital Markets Act Consultation (the Consultation). PMAC represents over 300 investment management firms registered to … Continue reading

January 31, 2022

PMAC Submission on 2021 OBSI Consultation

Overview The Portfolio Management Association of Canada (PMAC) represents over 300 investment management firms from across Canada registered with the various members of the Canadian Securities Administrators (CSA) as Portfolio Managers (PMs). PMAC’s membership is comprised of firms of varying … Continue reading

January 27, 2022

PMAC Submission – CSA Climate Disclosure for Reporting Issuers

Background PMAC’s response to the Consultation is from the perspective of portfolio managers as investors, though some of our members have affiliates and/or manage funds that are reporting issuers. Our comments are limited to those pertinent to the interests of … Continue reading

January 10, 2022

PMAC Submission to Australian Treasury 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 exposure draft legislation: Relief to Foreign Financial Service Providers Consultation Paper (the Consultation) issued by the Australian Treasury. … Continue reading