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Category: Submissions to Government

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 […]

Proposed Amendments to BC Instrument 22-502

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments on the British Columbia Securities Commission (BCSC) Notice and Request for Comment – Proposed Amendments to BC Instrument 22-502 Registration by the Investment Industry Regulatory Organization of Canada (Consultation). The key recommendations were: Implement strong oversight of […]

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 […]

United States legislation, H.R.1 – One Big Beautiful Bill Act

PMAC wrote to the Minister of Finance, François-Philippe Champagne, to urge the government to focus on proposed United States legislation, H.R. 1 – One Big Beautiful Bill Act, section 899 in particular. This bill would substantially increase taxes payable by Canadian individuals and businesses investing in the United States, including pension plans. It would also […]

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 […]

Opportunity to Improve Retail Investor Access to Long-Term Assets through Investment Fund Product Structures

PMAC responded to the OSC’s consultation into a framework to make long-term assets available to retail investors through investment fund structures. PMAC is supportive of efforts to increase diversification opportunities for retail investors but encouraged the OSC to appropriately balance these opportunities with the significant risks involved with investing in illiquid, long-term assets. In particular, […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 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 […]