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Author: Emily Lall

PMAC Submission on the CSA’s Proposed Liquidity Risk Management Framework

PMAC has submitted our response to the Canadian Securities Administrators’ (CSA) proposed amendments to National Instrument 81-102 Investment Funds (the Proposed Amendments) and the accompanying consultation paper on liquidity risk management tools, liquidity classification, regulatory reporting, and investor disclosure (the Consultation Paper). In our submissions, we express support for the CSA’s objectives of enhancing investor […]

Unlocking Capital and Competitiveness: PMAC and CFA Societies Canada Urge Ontario to Advance OSC Participation in the Passport System

On March 23, 2026, PMAC and CFA Societies Canada jointly submitted a letter to the Ontario Minister of Finance encouraging Ontario to move forward with the OSC’s participation in the CSA’s Passport System.  The letter outlines how participation would reduce interprovincial barriers, improve access to capital, and support Ontario’s broader competitiveness and economic integration objectives. […]

PMAC Submission – Proposed Multilateral Instrument 45-111 Self-Certified Investor Prospectus Exemption

We applaud the participating jurisdictions for taking steps to harmonize the self-certified investor prospectus exemption among them. We believe that making the eligibility criteria and the application of the exemption consistent among jurisdictions will result in less confusion, improved compliance with the exemption and ultimately will improve outcomes for registrants, issuers and investors. Clients of […]

PMAC submission on OSC Statement of Priorities for Fiscal Year 2026-2027

PMAC responded to the OSC’s Statement of Priorities for 2026-27.  Our key recommendations are for the OSC to: Join the CSA passport system; and Refrain from delegating any further registration responsibilities to the Canadian Investment Regulatory Organization (CIRO).   In our view, OSC participation in the CSA passport system for registration, prospectus review, and exemptive […]

PMAC Submission – Permit Semi-Annual Reporting for Certain Venture Issuers

PMAC acknowledges the work the CSA is doing to reduce regulatory burden and increase competition in Canada’s capital markets, especially given the current economic uncertainty. Providing blanket exemptions from certain continuous disclosure requirements and establishing the voluntary semi-annual reporting framework may contribute to reducing regulatory burden for the relevant issuers. There may also be a […]

PMAC Submission on the Draft Legislative Amendments to the Qualified Investments Regime

PMAC supports the proposed modernization of the qualified investments regime announced in Budget 2025. In our submission to the Department of Finance, we identified three areas where targeted refinements would improve clarity, reduce uncertainty, and maintain investor confidence: The proposed reliance on the existing statutory definition of “investment fund,” which was designed for a different […]

CSA Consultation on Exchange-Traded Fund Regulation

PMAC responded to the CSA’s consultation about the regulatory regime for exchange-traded funds. We did not agree with the prescriptive regulatory regime proposed by the CSA in the consultation and encouraged the CSA to ensure that any additional burden placed on firms is justified by evidence and subject to a rigorous cost/benefit analysis. Our key […]

PMAC calls on CSA to review privacy and data protection policies

PMAC calls on CSA to review privacy and data protection policies PMAC wrote to the Canadian Securities Administrators (CSA) following the cybersecurity incident at CIRO, which impacted registrants’ personal information.  We believe this incident serves as an opportunity for CIRO, the CSA and CSA member jurisdictions to review their privacy and data protection policies and […]

AMF discussion paper on account transfers

PMAC responded to the AMF Issues and Discussion Paper on account transfers in the financial sector.  Our key recommendations were: Implement cross-sector timelines for standard account transfers but allow flexibility for complex transactions; Harmonize requirements and exceptions between the CSA, CIRO and other regulators; Pursue a technology solution that is cost-effective and acceptable to firms […]

CIRO consultation on account transfers

PMAC responded to the CIRO consultation regarding Modernization of requirements for account transfers and bulk account movements. Our key recommendations were: Implement timelines for standard account transfers but allow flexibility for complex transactions; Harmonize requirements and exceptions between CIRO, the CSA and other regulators;  Pursue a technology solution that is cost-effective and acceptable to firms […]

PMAC submission – CSA 25-314 OBSI framework

PMAC Submission – CSA consultation on oversight framework and binding authority for OBSI PMAC responded to the CSA’s revised proposal to provide binding authority to OBSI, and to develop an oversight framework for OBSI.  We supported the changes made to the binding decision-making framework, including the addition of a process to have independent decision-makers review […]

PMAC comment letter – OSC short selling consultation

PMAC responded to the Ontario Securities Commission consultation regarding short selling in connection with prospectus offerings and private placements. We strongly believe that there is a risk that over-regulation of short selling activity could have negative consequences for market efficiency, because such restrictions can impede price discovery and curtail legitimate investing activity. In addition, short […]

PMAC Comment Letter – Department of Finance Pre-Budget Consultation

PMAC wrote to the Minister of Finance and National Revenue proving proposed amendments to the Amend the Income Tax Act (ITA. Including: Amend the Income Tax Act (ITA) to allow pooled investment funds to merge on a tax-deferred basis and to invest internationally without restriction  Implement the policy proposals released by the Canadian Asset Management […]

CSA Staff Notice and Consultation 11-348 – Applicability of Canadian Securities Laws and the Use of Artificial Intelligence Systems in Capital Markets

PMAC responded to the CSA’s consultation on the use of artificial intelligence systems in the capital markets.  Our key recommendations are: Maintain a principles-based, risk-based and flexible approach to emerging technologies such as AI, and adapt existing regulations where possible rather than enacting new requirements Continue to monitor the uses of AI in the asset […]

IRT Summary 02-25-2025

IRT Summary 03-25-2025 IRT Summary 02-25-2025   https://pmac.org/wp-content/uploads/2025/03/PMAC-IRT-Agenda-April-2025.pdf

PMAC IRT Agenda – 03-25-2025

This content is for PMAC portfolio management members only.    If you are part of an Affiliate membership, this content is unavailable to you.

This content is for PMAC portfolio management members only.    If you are part of an Affiliate membership, this content is unavailable to you.

PMAC Submission – Modernization of the Continuous Disclose Regime

KEY RECOMMENDATIONS: 1. Introduce the Fund Report changes to come into effect concurrently with or subsequent to the TCR Amendments coming into force, with initial reports being provided in 2027 at the earliest Many IFMs will rely on third party service providers to create the report, which requires a longer timeframe to make necessary changes. […]

PMAC letter to CRA – Capital Gains tax relief request

PMAC wrote to the Canada Revenue Agency regarding the proposed changes to the capital gains inclusion rate.  In light of the prorogation of Parliament and the upcoming federal election, there is significant uncertainty regarding the likelihood that the tax bill will be introduced or passed. As a result, many taxpayers may reasonably decide to file […]

IRT Summary-09-24-2024

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OBSI consultation on loss calculation methodology

PMAC is supportive of fair dispute resolution mechanisms and effective and trusted avenues for the redress of investor losses. As such, PMAC generally agrees with them OBSI’s current approach to loss calculations involving illiquid securities that have been found to be unsuitable for the investor. We believe that there are always exceptional and unforeseeable circumstances […]

PMAC Announces 2024-2025 Board of Directors

Toronto, ON – November 14, 2024 – The Portfolio Management Association of Canada (PMAC) is pleased to announce its Board of Directors for 2024-2025. The slate of Directors was elected at the Association’s 73rd Annual General Meeting (AGM) this week. Click here to read more.

Disgorgement Orders Consultation

PMAC agrees with the policy rationale of the Proposed Rules and welcomes the creation of a process that would increase distributions of disgorged amounts to the investors who have been harmed by sanctionable conduct. PMAC believes the Proposed Rules are a positive development for investors but could be improved upon to further protect investors by […]

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Competition Act Greenwashing Provisions

PMAC responded to the Competition Bureau’s consultation regarding the new Competition Act greenwashing provisions (Provisions). PMAC commented that, given the rapidly evolving area of responsible investing globally, we would strongly suggest that direct consultation with the CSA, the provincial securities regulatory authorities, and industry participants to discuss the practical implications of the Provisions, would be […]

CIRO Proficiency Consultation

PMAC responded to CIRO’s Proposed Proficiency Model to support CIRO’s decision to maintain high proficiency standards for CIRO-regulated Portfolio and Assistant Portfolio Managers, in alignment with comparable requirements under National Instrument 31-103 Registration Requirements, Exemptions, and Ongoing Registrant Obligations. You can read PMAC’s full submission here.

Consultation on Proposed Amendments to the Income Tax Act

PMAC responded to the Department of Finance’s consultation about proposed amendments to Canada’s Income Tax Act regarding enhanced reporting requirements for trust reporting and the proposed excessive interest and financing expense limitation (EIFEL) rules. PMAC welcomes the additional clarity to the enhanced trust beneficiary reporting requirements provided by the Department of Finance’s proposed amendments released […]