December 20, 2023

PMAC Submission – CIRO Rule Consolidation Project – Phase 1

PMAC Submission – CIRO Rule Consolidation 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 … Continue reading →

December 18, 2023

PMAC Submission – OSC Notice 11-798 – Statement of Priorities

  PMAC Submission – 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 … Continue reading →

December 7, 2023

PMAC Submission – 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 … Continue reading →

December 5, 2023

PMAC Submission – Less Red Tape, More Common Sense Act, 2023

Re: Proposed amendments to the Securities Act, Commodity Futures Act, and the Financial Services Regulatory Authority of Ontario Act, 2016 OVERVIEW The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry … Continue reading →

October 2, 2023

PMAC Submission on 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 … Continue reading →

August 23, 2023

PMAC Submission on Treasury Laws Amendments

Submission to Australian Treasury on Licensing exemptions for foreign financial services providers 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 … Continue reading →

August 2, 2023

PMAC Submission on Department of Finance’s consultation paper on Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime

Overview The 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 … Continue reading →

March 16, 2023

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 … Continue reading →

March 16, 2023

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 … Continue reading →

March 8, 2023

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 … Continue reading →

February 17, 2023

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 … Continue reading →

February 13, 2023

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 … Continue reading →

January 31, 2023

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, … Continue reading →