Submissions archive

April 28, 2022

PMAC Comment Letter – Modernization of the Prospectus Filing Model for Investment Funds

Overview The Portfolio Management Association of Canada (PMAC), is pleased to have the opportunity to submit the following comments regarding the CSA Notice and Request for Comment – Proposed Amendments to National Instrument 41-101 General Prospectus Requirements, National Instrument 81-101 … Continue reading

April 20, 2022

PMAC Comment Letter on 2022 OSC Fees Consultation

Overview The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding Proposed Amendments to OSC Rule 13-502 Fees, OSC Rule 13-503 (Commodity Futures Act) Fees and Proposed Changes to their Companion … Continue reading

April 5, 2022

PMAC Submission to Department of Finance on draft tax proposals

Trust reporting requirement exemption should include pooled funds The lack of MFT status for pooled funds results in several unfair consequences compared to mutual funds and segregated funds. This inequity includes the impacts of the proposed trust beneficial ownership reporting … Continue reading

March 21, 2022

PMAC Submission to CSA on 2022 Derivatives Business Conduct Consultation

OVERVIEW The Portfolio Management Association of Canada (PMAC), through our Industry Regulation & Taxation Committee, is pleased to have the opportunity to submit the following comments regarding the CSA’s Notice and Third Request for Comment – Proposed National Instrument 93-101 … Continue reading

February 28, 2022

PMAC submission on Federal Pre-Budget Consultations 2022

  The Portfolio Management Association of Canada (PMAC) represents over 300 investment management firm members that collectively manage $3 trillion in assets for pension plans, endowments, individual and group RSPs, and other investments across Canada. We are writing to ask … Continue reading

February 18, 2022

PMAC Comments on the Ontario Capital Markets Act Consultation Draft

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry of Finance (Ministry) on the Capital Markets Act Consultation (the Consultation). PMAC represents over 300 investment management firms registered to … Continue reading

January 31, 2022

PMAC Submission on 2021 OBSI Consultation

Overview The Portfolio Management Association of Canada (PMAC) represents over 300 investment management firms from across Canada registered with the various members of the Canadian Securities Administrators (CSA) as Portfolio Managers (PMs). PMAC’s membership is comprised of firms of varying … Continue reading

January 27, 2022

PMAC Submission – CSA Climate Disclosure for Reporting Issuers

Background PMAC’s response to the Consultation is from the perspective of portfolio managers as investors, though some of our members have affiliates and/or manage funds that are reporting issuers. Our comments are limited to those pertinent to the interests of … Continue reading

January 10, 2022

PMAC Submission to Australian Treasury on Relief to Foreign Financial Service Providers

Overview The Portfolio Management Association of Canada (PMAC), through its International Committee, is pleased to have the opportunity to respond to the exposure draft legislation: Relief to Foreign Financial Service Providers Consultation Paper (the Consultation) issued by the Australian Treasury. … Continue reading

December 17, 2021

PMAC Comment Letter – OSC Statement of Priorities For Financial Year to End 2023

Overview PMAC is supportive of the four overarching goals set out in the Statement of Priorities. We are pleased to have the opportunity to provide the following feedback on certain aspects of them. Read the full submission here.

December 15, 2021

PMAC Submission – FSRA Financial Planner and Financial Advisor Rule and Guidance

Background As noted in our July 5th submission to FSRA, PMAC believes that the proposed regulation of the Financial Planner (FP) title presents an opportunity to achieve two important goals: (i) level the playing field for those providing financial planning … Continue reading

December 10, 2021

PMAC Submission – AMF Consultation on Regulation respecting complaint processing and dispute resolution in the financial sector

PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that elevate standards in the industry and improve investor protection. PMs generally manage client assets on a discretionary basis; they are subject to the highest proficiency standards in … Continue reading

October 25, 2021

PMAC Submission – New Brunswick Financial Planner and Financial Advisor Rule

Overview The Portfolio Management Association of Canada1 (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the Financial and Consumer Services Commission of New Brunswick (FCNB)’s consultation notice – Title Protection 2021 … Continue reading

October 4, 2021

PMAC Comment – CSA Position Paper 25-404 New Self-Regulatory Organization Framework

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Canadian Securities Administrators (CSA) on CSA Position Paper 25-404 – New Self-Regulatory Organization Framework (the Position Paper). PMAC represents over … Continue reading

October 1, 2021

PMAC Submission on Saskatchewan Financial Planners and Financial Advisors Regulations

The Portfolio Management Association of Canada (“PMAC“), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the request for comment from the Financial and Consumer Affairs Authority of Saskatchewan (FCAA) on Proposed Regulations … Continue reading

September 29, 2021

PMAC Response to the CFA Institute’s Diversity, Equity and Inclusion Code

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors and individuals alike. Read PMAC’s the full response to the CFA Institute’s Diversity, Equity and Inclusion (DE&I) Code here … Continue reading

September 7, 2021

PMAC Submission on Ontario Privacy Consultation

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). PMAC has been supportive of proposals that provide assurances to individuals that their privacy … Continue reading

August 26, 2021

PMAC submissions to Canada Revenue Agency (CRA) on draft revised Guidance for FATCA and CRS

PMAC responded to the CRA’s consultation draft revised guidance with respect to FATCA and CRS. Read the submission on CRS here and on FATCA here.

August 16, 2021

PMAC Submission – IOSCO Consultation Report: Recommendations for Sustainability-Related Practices, Policies, Procedures and Disclosures in Asset Management

Overview The Portfolio Management Association of Canada (PMAC), with the assistance of a member working group consisting of CFAs and ESG experts, is pleased to have the opportunity to submit the following comments regarding the International Organization of Securities Commissions … Continue reading

August 4, 2021

PMAC Submission – Special Committee to Review the Personal Information Protection Act

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to respond to British Columbia’s (BC) request for comments on modernizing the Personal Information Protection Act (Consultation). PMAC is supportive of BC’s efforts to enhance British Columbians’ individual … Continue reading

August 4, 2021

PMAC Submission on Relief to Foreign Financial Service Providers

Overview The Portfolio Management Association of Canada (PMAC), through its International Committee, is pleased to have the opportunity to respond to the request for comment regarding the Relief to Foreign Financial Service Providers Consultation Paper (the Consultation) issued by the … Continue reading

July 27, 2021

PMAC Comments on Proposed British Columbia Instrument 51-519 Promotional Activity Disclosure Requirements.

Overview PMAC agrees that any form of market manipulation or investor deception must be deterred and appropriately punished. We are generally of the view that regulation should be focused on specific behaviours and desired outcomes. We believe that the Consultation … Continue reading

July 15, 2021

PMAC Submission – Exposure Draft – CFA Institute ESG Disclosure Standards for Investment Products

Overview The Portfolio Management Association of Canada (PMAC), through a working group consisting of CFAs and ESG experts and through its wider Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding the … Continue reading

July 5, 2021

PMAC Submission on FSRA Financial Planner and Financial Advisor Rule and Guidance 2021

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the request for comment from the Financial Services Regulatory Authority of Ontario (FSRA) regarding its updated … Continue reading

June 11, 2021

PMAC Comment on Saskatchewan FCAA Pension Solvency Funding Review

Overview PMAC is supportive of the FCAA’s goal of seeking stakeholder feedback on options to amend the solvency funding framework for single employer private sector pension plans (SEPPPs) under The Pension Benefits Act, 1992 (Act) and the Pension Benefits Regulations, … Continue reading

May 5, 2021

PMAC Submission – CSA on Proposed Amendments to NI 33-109 – modernizing registration information requirements, clarifying outside activity reporting and updating filing deadlines

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to respond to CSA Notice and Request for Comment on Proposed Amendments to National Instrument 33-109 – Registration Information (NI 33-109) and Changes to Companion Policy … Continue reading

March 18, 2021

PMAC Submission – CSA Consultation Paper 25-403 – Activist Short Selling

OVERVIEW PMAC generally favours principles-based regulation that recognizes differences in business models, sizes, and client types. We support the CSA’s decision to consult with stakeholders on the important issues raised in the Consultation. Given the fast pace of change in … Continue reading

March 12, 2021

PMAC Comment on Bill C-11, Digital Charter Implementation Act 2020

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). Portfolio managers have a fiduciary duty to act with care, honestly and in good … Continue reading

March 1, 2021

PMAC submission on the OSC Exemptive relief for international firms under CFA and Securities Act

Re: OSC Notice and Request for Comment – Proposed OSC Rule 32-506 (Under the Commodity Futures Act) Exemptions for International Dealers, Advisers and Sub-Advisers and Proposed amendment to OSC Rule 91-502 Trades in Recognized Options under the Securities Act The … Continue reading

February 23, 2021

PMAC Submission on the Ontario 2021 Budget Consultations

The Portfolio Management Association of Canada (PMAC) appreciates the opportunity to comment on the 2021 budget, with a focus on the recommendations of the Capital Markets Modernization Taskforce (Taskforce). We urge Ontario to continue to support the Cooperative Capital Markets … Continue reading

January 14, 2021

PMAC Submission on Federally Regulated Private Pension Plans

Re: Strengthening Canadians’ Retirement Security – Proposals to Support the Sustainability of and Strengthen the Framework for Federally Regulated Private Pension Plans OVERVIEW The Portfolio Management Association of Canada (PMAC), through its pensions advocacy committee, is pleased to have the … Continue reading

December 16, 2020

PMAC Submission on OSC Statement of Priorities for Financial Year to End 2022

OVERVIEW PMAC is supportive of the four overarching goals set out in the Statement of Priorities and we are pleased to have the opportunity to provide the following feedback on certain aspects of them. We have made several recent submissions … Continue reading

December 7, 2020

PMAC submission on Quebec Bill 64

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). PMAC’s member firms believe that privacy legislation needs to be modernized and streamlined in … Continue reading

November 13, 2020

PMAC Submission to FSRA on FP/FA title regulation

Background The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the request for comment from the Financial Services Regulatory Authority of Ontario (FSRA) on Proposed Rule … Continue reading

October 23, 2020

PMAC Submission on CSA Consultation Paper 25-402 Consultation on the Self-Regulatory Organization Framework

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Canadian Securities Administrators (CSA) on CSA Consultation Paper 25-402 Consultation on the Self-Regulatory Organization Framework (the Consultation). PMAC represents over … Continue reading

October 20, 2020

PMAC Submission on CFA Institute ESG Standards Consultation

OVERVIEW The Portfolio Management Association of Canada (PMAC), through a working group consisting of CFAs and ESG experts and through its wider Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding the … Continue reading

September 22, 2020

PMAC Submission on Shared CCO Models

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding CSA Staff Notice 31-358 – Guidance on Registration Requirements for Chief Compliance Officers … Continue reading

September 4, 2020

Consultation — Modernizing Ontario’s Capital Markets

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Capital Markets Modernization Taskforce (CMMT) for your consideration, further to our meeting with the CMMT on May 11th and the publication … Continue reading

August 14, 2020

Financial Industry Request for Transition Period with respect to penalties

On behalf of the CBA, IIAC, IFIC, and PMAC, we want to acknowledge and thank you for the collaboration and assistance the CRA and the federal government has provided the financial services industry with respect to the “Guidance on the … Continue reading

July 16, 2020

CSA Notice and Request for Comment – Proposed Amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations and Companion Policy to Enhance Protection of Older and Vulnerable Clients

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding CSA Notice and Request for Comment – Proposed Amendments to National Instrument 31-103 … Continue reading

July 3, 2020

PMAC Submission on Proposed OSC Rule 81-502 – Restrictions on the Use of the Deferred Sales Charge Option for Mutual Funds

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding OSC Notice and Request for Comment – Proposed Ontario Securities Commission Rule 81-502 Restrictions on the Use of the Deferred … Continue reading

May 1, 2020

PMAC Submission to Department of Finance Canada – Challenges Posed by COVID-19 to Federally-regulated Pension Plans

Background The Portfolio Management Association of Canada (PMAC) wrote to comment on an issue of impact to member firms and intensified by market conditions arising from by the COVID-19 pandemic. PMAC represents over 280 asset management firms, collectively managing over … Continue reading

March 5, 2020

PMAC Submission on CSA Consultation Paper 51-405 – Consideration of an Access Equals Delivery Model for Non-Investment Fund Reporting Issuers

Background The Portfolio Management Association of Canada (PMAC) was pleased to have the opportunity to submit the following comments regarding CSA Consultation Paper 51-405 – Consideration of an Access Equals Delivery Model for Non-Investment Fund Reporting Issuers (the Consultation). PMAC … Continue reading

February 27, 2020

PMAC Submission on Manitoba Bill 8 – The Pension Benefits Amendment Act

Overview The pension committee of the Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide member feedback in respect of Bill 8 – the Pension Benefits Amendment Act (Bill 8). PMAC is pleased to see … Continue reading

February 19, 2020

Submission on Department of Finance Pre-budget Consultations

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, provided comments to the Department of Finance Canada (Finance) regarding Pre-budget Consultations 2020 (the Consultation). PMAC represents 280 investment management firms that collectively manage over … Continue reading

December 11, 2019

PMAC submission on Reducing Regulatory Burden for Investment Fund Issuers – Phase 2, Stage 1

Overview The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding CSA Notice and Request for Comment – Reducing Regulatory Burden for Investment Fund Issuers – Phase 2, Stage 1 (the … Continue reading

December 4, 2019

PMAC submission on CSA Notice and Request for Comment – Proposed Amendments to National Instrument 51-102

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding CSA Notice and Request for Comment – Proposed Amendments to National Instrument 51-102 … Continue reading

November 28, 2019

PMAC submission on Support for the creation of the Cooperative Capital Markets Regulatory System (the Cooperative System)

OVERVIEW The Portfolio Management Association of Canada (PMAC) wrote the Governments of Ontario and British Columbia to voice our support of their participation in the creation of the Cooperative Capital Markets Regulatory System (the Cooperative System). PMAC represents over 275 … Continue reading

September 18, 2019

PMAC submission on Discussion paper: “Strengthening Privacy for the Digital Age”

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding the Government of Canada’s proposals via the Ministry of Innovation, Science and Economic Development to amend the Personal Information Protection and … Continue reading

September 9, 2019

PMAC submission on Consultation on the regulation of financial planners and financial advisors

Overview The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to comment on the consultation with respect to the regulation of financial planners and financial advisors issued by the Financial and Consumer Affairs Authority of Saskatchewan … Continue reading