The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Notice and Request for Comment – Modernization of Investment Fund Product Regulation – Alternative Funds (the “Proposed Amendments”).
Capitalized terms used in this letter but not defined herein have the same meaning given to them in the Proposed Amendments.
Overview
PMAC represents investment management firms registered to do business in Canada as portfolio managers. PMAC members encompass both large and small firms managing total assets in excess of $1.5 trillion for institutional and private client portfolios. We advocate for the highest standards of unbiased portfolio management in the interest of the investors served by our members.
PMAC is appreciative of the CSA’s innovative, thoughtful and ongoing policy work to modernize investment fund product regulation (the “Modernization Project”) in a way that focuses on investor protection while reflecting the significant expansion of investment fund products and strategies available in the market.