Submissions archive

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

August 29, 2019

PMAC Submission on A Review of the Solvency Funding Framework under the Pensions Benefits Standards Act: A Consultation Paper

Background The Portfolio Management Association of Canada[1] (PMAC) is pleased to have the opportunity to provide feedback on the Ministry of Finance’s (Ministry) consultation with respect to “A Review of the Solvency Funding Framework under the Pensions Benefits Standards Act: … Continue reading

August 1, 2019

PMAC submission on OPC Consultation on Transborder Dataflows

PMAC’s mission statement is “advancing standards” and we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). PMAC and its members care deeply about the protection and proper use of investors’ … Continue reading

July 31, 2019

PMAC submission on MFDA Consultation on Limited Discretionary Trading

PMAC supports regulatory flexibility and burden reduction that enables improved service, innovation, or a reduction in costs borne by investors. We understand that the MFDA is seeking to permit its Members to rebalance model portfolios in a time and cost-effective … Continue reading

July 30, 2019

PMAC submission on CSA National Systems Renewal and System Fee

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 National Systems Renewal Program Rule and … Continue reading

May 27, 2019

PMAC submission on OSC Notice 11-785 Statement of Priorities for Financial Year to End March 31, 2020

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 OSC Notice 11-785 Statement of Priorities – Request for Comments Regarding Statement of Priorities … Continue reading

May 15, 2019

PMAC submission on Communication of Key Audit Matters in the Auditor’s Report

BACKGROUND  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 the proposed revisions to Canadian Audit Standard 700, Forming an Opinion and Reporting … Continue reading

March 1, 2019

PMAC Submission on OSC Internal Taskforce on Regulatory Burden Reduction

The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is making this submission to the Ontario Securities Commission (OSC) to assist in the formulation of priorities for the OSC’s regulatory burden reduction taskforce. On behalf … Continue reading

January 28, 2019

PMAC submission on BC Defined Benefit Pension Plan Solvency Funding Framework Review

The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee’s sub-committee on pensions, is pleased to have the opportunity to participate in the Ministry of Finance’s (Ministry) consultation with respect to “A Review of the Solvency … Continue reading

December 21, 2018

PMAC submission on OSC Internal Taskforce on Regulatory Burden Reduction

The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is making this submission to the Ontario Securities Commission (OSC) to assist in the formulation of priorities for the OSC’s regulatory burden reduction taskforce. On behalf … Continue reading

December 13, 2018

PMAC submission on CSA Notice and Request for Comment: Proposed Amendments to NI 81-105 – Mutual Fund Sales Practices and Related Consequential Amendments

Overview and background The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (CSA) notice and request for comment on proposed amendments … Continue reading

November 29, 2018

PMAC submission on Rules for Defined Benefit Pension Plans: Description of New Funding Rules

The Portfolio Management Association of Canada (“PMAC“), through its Industry, Regulation & Tax Committee, is writing to comment on an issue of impact to member firms arising out of the province of Ontario’s 2018 finalization of legislation and regulations regarding … Continue reading

October 19, 2018

PMAC response to CSA Notice and Request for Comment – Proposed Amendments to National Instrument 31-103 – Client Focused Reforms

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to provide comments on the Canadian Securities Administrators’ (CSA) notice and request for comment on proposed amendments to National Instrument 31-103 – Registration … Continue reading

September 17, 2018

PMAC response to CSA Notice and Request for Comment – Proposed National Instrument 93-102 – Derivatives: Registration and Proposed Companion Policy 93-102 – Derivatives: Registration

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on Proposed National Instrument 93-102 – Derivatives: Registration and Proposed Companion Policy 93-102 – Derivatives: Registration … Continue reading

September 17, 2018

PMAC response to CSA Second Notice and Request for Comment – Proposed National Instrument 93-101 – Derivatives: Business Conduct and Proposed Companion Policy 93-101CP – Derivatives: Business Conduct

OVERVIEW The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the second notice and request for comment published by the Canadian Securities Administrators (CSA) titled … Continue reading

September 10, 2018

PMAC submission on the Consultation by the Department of Finance Canada on draft tax legislative proposals relating to Budget 2018

The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on Department of Finance Canada (Finance) – Consulting Canadians on Draft Tax Legislative Proposals (the Consultation). General … Continue reading

September 6, 2018

PMAC submission on Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act

Overview The 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 Regulations amending certain regulations made under the … Continue reading

August 7, 2018

PMAC submission on CMRA Regulation 45-501 – Prospectus and Registration Exemptions

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide the Cooperative Capital Markets Regulatory System (CCMRS) with comments on the CMRA Regulation 45-501 – Prospectus and … Continue reading

July 24, 2018

PMAC submissions on the Discussion Paper on Expanding Cost Reporting

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide the Mutual Fund Dealers Association of Canada (MFDA) with comments on the Discussion Paper on Expanding Cost … Continue reading

May 28, 2018

PMAC submission on OSC Notice 11-780 – Statement of Priorities

Re:  OSC Notice 11-780 Statement of Priorities – Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2019 The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to … Continue reading

May 17, 2018

PMAC Submission on Department of Finance Anti-Money Laundering Consultation

 Overview The 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 paper titled, Reviewing Canada’s Anti-Money Laundering … Continue reading

April 16, 2018

PMAC Submission on Ontario Consultation on Regulation of Financial Planners

Overview The Portfolio Management Association of Canada[1] (“PMAC“), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to comment on the consultation paper on the regulation of financial planners (the Consultation) issued by the Ontario Ministry … Continue reading

April 3, 2018

PMAC Submission on BCSC Notice and Request for Comment – Consulting on the Securities Law Framework for Fintech Regulation

GENERAL The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee’s securities sub-committee, is pleased to have the opportunity to provide comments on the Notice and Request for Comment from the British Columbia Securities Commission (BCSC) … Continue reading

January 29, 2018

PMAC Submission on Reform of Ontario’s Funding Rules for Defined Benefit Pension Plans

Re: Reform of Ontario’s Funding Rules for Defined Benefit Pension Plans: Description of New Funding Rules The Portfolio Management Association of Canada1 (PMAC), through its Industry, Regulation & Tax Committee’s sub-committee on pensions, is pleased to have the opportunity to … Continue reading

November 21, 2017

PMAC Response to Canadian Competition Bureau’s draft FinTech Report

OVERVIEW The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Competition Bureau’s Public Consultation on the draft report of its market study concerning technology-led … Continue reading

September 6, 2017

PMAC submission on CSA Notice and Request for Comment on Proposed National Instrument 93-101 – Derivatives: Business Conduct and Proposed Companion Policy 93-101CP – Derivatives: Business Conduct

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Notice and Request for Comment – Proposed National Instrument 93-101 – … Continue reading

August 9, 2017

PMAC submission on IIROC Notice: Proposed Amendments to Client Identification and Verification Requirements

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments IIROC’s Notice on Proposed Amendments to Client Identification and Verification Requirements (the “Proposed Amendments”). Capitalized terms used … Continue reading

July 24, 2017

PMAC feedback on recent developments and publications by the Ombudsman for Banking Services and Investments & Ongoing Service Provision to Portfolio Managers by OBSI

OVERVIEW The Portfolio Management Association of Canada (“ PMAC“) represents over 240 investment management firms from across Canada that manage total assets in excess of $1.5 trillion, with a mix of both institutional and private client assets. PMAC is very supportive … Continue reading

June 9, 2017

Canadian Securities Administrators Consultation Paper 81-408 – Consultation on the Option of Discontinuing Embedded Commissions

  The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Consultation Paper 81-408 – Consultation on the Option of Discontinuing … Continue reading

May 25, 2017

OSC Notice 11-777 Statement of Priorities – Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2018

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 OSC Notice 11-777 Statement of Priorities  –  Request for Comments Regarding Statement of Priorities … Continue reading

May 18, 2017

Final Report of the Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives

The Portfolio Management Association of Canada[1] (“PMAC“), through its Industry, Regulation & Tax Committee, was pleased to have the opportunity to participate in the Ontario government consultation process regarding Financial Advisory and Financial Planning Policy Alternatives (the “Consultation”) in 2016 … Continue reading

February 15, 2017

Exchanges’ Request for Comments on Required Insider Reports

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Request for Comments from TSX Inc. and TSX Venture Exchange Inc. (the “Exchanges”) with respect … Continue reading

December 22, 2016

CSA Notice and Request for Comment – Modernization of Investment Fund Product Regulation – Alternative Funds

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Notice and Request for Comment – Modernization of Investment Fund Product … Continue reading

October 5, 2016

Proposed Amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations, the Companion Policy to NI 31-103, National Instrument 33-109 – Registration Information and Related Forms

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Proposed Amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations, … Continue reading

September 29, 2016

Review of Ontario’s Solvency Funding Framework for Defined Benefit Pension Plans

The Portfolio Management Association of Canada (“PMAC“), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to participate in the Ministry of Finance’s review of Ontario’s solvency funding framework for defined benefit pension plans (the “Consultation”). … Continue reading

September 27, 2016

Canadian Securities Administrators Consultation Paper 33-404 – Proposals To Enhance the Obligations of Advisers, Dealers, and Representatives Toward Their Clients

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Consultation Paper 33-404 – Proposals To Enhance the Obligations of Advisers, Dealers, and Representatives … Continue reading

September 16, 2016

Pension Plan Investment in Canada: The 30 Per Cent Rule

The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is writing to express our views on the ongoing usefulness of the 30 per cent rule and considerations relating to its elimination pursuant to the Federal government’s consultation on … Continue reading

August 18, 2016

Draft Regulations under the Pooled Registered Pensions Plans Act 2015

The Portfolio Management Association of Canada (“PMAC“), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to participate in the consultation process regarding the draft regulations (the “Regulations”) under the Ontario Pooled Registered Pension Plans Act, 2015 (the … Continue reading