CIRO Rule Consolidation Project – Phase 1
PMAC generally supports the objectives of the Consultation and agree that the rules pertaining to Investment Dealers (IDs) and Mutual Fund Dealers (MFDs) should be harmonized to minimize regulatory arbitrage. KEY RECOMMENDATIONS Eliminate the offering of discretionary account arrangements; in the interim, limit the dealer types that can offer this account type to investment dealers […]
OSC Notice 11-798 – Statement of Priorities
OSC consultation on its Proposed Statement of Priorities for Fiscal Year 2024-2025 On November 16, 2023, the OSC published for a 30-day comment period its proposed Statement of Priorities for the Fiscal Year 2024-2025 (SoP) that provides a list of the OSC’s priorities and associated activities. The OSC will consider stakeholder comments and make any […]
Designated Plan Trust
Draft Legislation in respect of “Designated Plan Trusts” Read the full submission here Summary Overview: The proposed draft legislation set out below establishes the new concept of a “designated plan trust”. The proposed amendments closely track the statutory/regulatory language that defines a “mutual fund trust” at subsections 132(6)-(7) and section 248 of the Income Tax […]
Less Red Tape, More Common Sense Act, 2023
Overview The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry of Red Tape Reduction and the Ministry of Finance (collectively, the Ministries) on the proposed amendments to the Securities Act, Commodity Futures Act, and the Financial Services Regulatory Authority of Ontario Act, 2016 under the […]
Corporate Governance
GENERAL COMMENTS PMAC applauds the Amendments to improve diversity disclosure beyond the representation of women, the proposed changes that provide guidelines related to board nominations and the introduction of guidelines on board renewal and board diversity. Not only will enhanced disclosure help investors make more informed decisions, but it is likely to precipitate other outcomes […]
Submission to Australian Treasury on Licensing exemptions for foreign financial services providers
Overview PMAC made a submission to the Australian Treasury in support of a proposed bill that would amend licensing exemptions for foreign financial services providers (FFSPs). Further to PMAC’s previous advocacy on this issue, we reiterated our support for Australian considering the OSC to be a “comparable regulator”, allowing firms registered with the OSC to […]
Department of Finance’s consultation paper on Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime
Overview he Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide the Department of Finance Canada (Finance) with comments on the consultation on Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime (the Consultation). Key Recommendations 1. Regulation should be principles-based and industry-specific We are […]
PMAC Submission on CSA Consultation on NI 24-101 – Institutional Trade Matching and Settlement
General Comments PMAC supports the work of the CSA to facilitate the move to a T+1 settlement cycle for equity and long-term debt market trades (T+1). PMAC also supports the direction taken by the CSA to not amend sections 9.4 and 10.4 of National Instrument 81-102 – Investment Funds at this time to shorten the […]
PMAC Submission on Department of Finance’s consultation paper on amendments to regulations made under the PCMLTFA
Support for the Consultation PMAC is supportive of Finance’s focus on reviewing Canada’s AML laws to ensure that they remain responsive to emerging risks and evolving international standards, including the Financial Action Task Force’s (FATF) standards as well as the findings and the recommendations made in the final report by the Cullen commission (the Cullen […]
PMAC Submission on Joint CSA and IIROC Staff Notice 23-329 Short Selling in Canada
Key Recommendations Do not make any immediate changes to the regulatory framework with respect to the Canadian short selling regime; and, Continue to conduct research and to consult with stakeholders regarding the frequency and root causes of failed trades and their relationship to short selling in Canada. Conclusion There does not appear to be […]
PMAC Submission – AMF Consultation on Regulation respecting complaint processing and dispute resolution in the financial sector
Overview As we noted in our response to the 2021 Consultation on this Draft Regulation (2021 response), PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that elevate standards in the industry and improve investor protection. We encourage the harmonization of regulatory requirements for asset managers across Canada and internationally where possible, […]
PMAC 2023 Pre-budget Submission to Department of Finance Canada
Executive Summary The issue Many Canadian employers offer Defined Contribution (DC) pension plans and other savings programs to their employees; these plans are an effective means of encouraging them to save for retirement. According to Statistics Canada, membership in employer sponsored DC pension plans continues to rise, accounting for approximately 20% of all pension plan […]
PMAC Submission on OBSI Corporate Governance Consultation
Key Recommendations Transition OBSI’s board to a fully fiduciary board of directors without designated stakeholder representatives from industry bodies and without a designated Consumer Interest Director to reduce inherent conflicts of interest. Appoint all Directors based on a skills matrix, ensuring that the board collectively has the knowledge and experience to act in the best […]
