PMAC Submission – OSC Notice 11-799 – Statement of Priorities – Request for Comments Regarding Statement of Priorities for Fiscal Year 2025-2026
PMAC is supportive of the Ontario Securities Commission’s (OSC) key priorities set out in the SoP, as well as the work plans supporting those goals. Any changes made by the OSC – be they regulatory or technical in nature – should be evidence-based and tested to ensure that the change is of benefit to investors […]
PMAC Submission – 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 Response – 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 […]
PMAC Response – 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 […]
PMAC Submission – 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.
PMAC Submission – 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 […]
CSSB Consultation on Adoption of CSDS 1 and CSDS 2 in Canada – Survey Response
Canadian Sustainability Standards Board draft standards PMAC responded to the Canadian Sustainability Standards Board (CSSB) consultation survey on its first two standards, general requirements regarding sustainability-related financial information (CSDS 1) and climate-related disclosure requirements (CSDS 2). These drafts mirror the standards issued by the International Sustainability Standards Board (ISSB), with changes to reflect the Canadian […]
CIRO Position Paper: Policy options for leveling the advisor compensation playing field
We recognize CIRO’s objective of harmonizing the rules applicable to Investment Dealers (IDs) and Mutual Fund Dealers (MFDs) in an effort to level the playing field for advisor compensation. Fundamentally, we believe that regulatory changes should not be rushed and need to be implemented properly to minimize investor protection risk and regulatory arbitrage. It’s also […]
PMAC Submission – CSA – Registered Firm Requirements Pertaining to an Independent Dispute Resolution Service
The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments on the Canadian Securities Administrators’ (CSA) Notice and Request for Comment – Registered Firm Requirements Pertaining to an Independent Dispute Resolution Service – Proposed Amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI […]
PMAC Submission – CIRO Rule Consolidation Project – Phase 1
PMAC generally supports the objectives of the Consultation and agree that the rules pertaining to Investment Dealers (IDs) and Mutual Fund Dealers (MFDs) should be harmonized to minimize regulatory arbitrage. KEY RECOMMENDATIONS Eliminate the offering of discretionary account arrangements; in the interim, limit the dealer types that can offer this account type to investment dealers […]
PMAC Submission – OSC Notice 11-798 – Statement of Priorities
OSC consultation on its Proposed Statement of Priorities for Fiscal Year 2024-2025 On November 16, 2023, the OSC published for a 30-day comment period its proposed Statement of Priorities for the Fiscal Year 2024-2025 (SoP) that provides a list of the OSC’s priorities and associated activities. The OSC will consider stakeholder comments and make any […]
PMAC Submission – Designated Plan Trust
Draft Legislation in respect of “Designated Plan Trusts” Read the full submission here Summary Overview: The proposed draft legislation set out below establishes the new concept of a “designated plan trust”. The proposed amendments closely track the statutory/regulatory language that defines a “mutual fund trust” at subsections 132(6)-(7) and section 248 of the Income Tax […]
PMAC Submission – Less Red Tape, More Common Sense Act, 2023
Overview The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry of Red Tape Reduction and the Ministry of Finance (collectively, the Ministries) on the proposed amendments to the Securities Act, Commodity Futures Act, and the Financial Services Regulatory Authority of Ontario Act, 2016 under the […]
PMAC Submission on Corporate Governance
GENERAL COMMENTS PMAC applauds the Amendments to improve diversity disclosure beyond the representation of women, the proposed changes that provide guidelines related to board nominations and the introduction of guidelines on board renewal and board diversity. Not only will enhanced disclosure help investors make more informed decisions, but it is likely to precipitate other outcomes […]
Submission to Australian Treasury on Licensing exemptions for foreign financial services providers
Overview PMAC made a submission to the Australian Treasury in support of a proposed bill that would amend licensing exemptions for foreign financial services providers (FFSPs). Further to PMAC’s previous advocacy on this issue, we reiterated our support for Australian considering the OSC to be a “comparable regulator”, allowing firms registered with the OSC to […]
PMAC Submission on Department of Finance’s consultation paper on Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime
Overview he Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide the Department of Finance Canada (Finance) with comments on the consultation on Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime (the Consultation). Key Recommendations 1. Regulation should be principles-based and industry-specific We are […]
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 Submission – AMF Consultation on Regulation respecting complaint processing and dispute resolution in the financial sector
Overview As we noted in our response to the 2021 Consultation on this Draft Regulation (2021 response), PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that elevate standards in the industry and improve investor protection. We encourage the harmonization of regulatory requirements for asset managers across Canada and internationally where possible, […]
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 […]
