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 into consideration and made significant efforts to adopt an investor protection lens in developing these proposals.

However, there are some instances where we believe the CSA could make further improvements to the governance provisions in By-Law No. 1. We have consulted with Dr. Richard Leblanc, a Professor of Governance, Law and Ethics at York University and a recognized expert on corporate governance. Dr. Leblanc has reviewed By-Law No. 1 and prepared the report attached hereto as Appendix A. We agree with his proposals, which are aligned with comments previously provided by PMAC in our 2020 and 2021 Letters. We encourage the CSA to adopt the changes Dr. Leblanc suggests to By-Law No. 1.

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