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 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 […]