The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the proposed amendments for Mutual Fund Risk Classification Methodology for Use in Fund Facts and ETF Facts (the “Proposal”). PMAC has generally been supportive of the CSA’s direction on mutual fund risk classification and the use of standard deviation. We are also supportive of some of the key changes from the 2013 proposal including the elimination of the six-category risk scale presented in the 2013 Proposal, to the standard five-category risk scale from low to high currently in the Fund Facts and in the proposed ETF Facts.
