Submissions archive

December 20, 2023

PMAC Submission – CIRO Rule Consolidation Project – Phase 1

PMAC Submission – CIRO Rule Consolidation 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 … Continue reading

December 18, 2023

PMAC Submission – OSC Notice 11-798 – Statement of Priorities

  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 … Continue reading

December 7, 2023

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 … Continue reading

December 5, 2023

PMAC Submission – Less Red Tape, More Common Sense Act, 2023

Re: Proposed amendments to the Securities Act, Commodity Futures Act, and the Financial Services Regulatory Authority of Ontario Act, 2016 OVERVIEW The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry … Continue reading

October 2, 2023

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 … Continue reading

August 23, 2023

PMAC Submission on Treasury Laws Amendments

Submission to Australian Treasury on Licensing exemptions for foreign financial services providers 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 … Continue reading

August 2, 2023

PMAC Submission on Department of Finance’s consultation paper on Strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime

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 on Strengthening Canada’s Anti-Money Laundering and … Continue reading

March 16, 2023

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 … Continue reading

March 16, 2023

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 … Continue reading

March 8, 2023

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 … Continue reading

February 17, 2023

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 … Continue reading

February 13, 2023

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 … Continue reading

January 31, 2023

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, … Continue reading

December 22, 2022

PMAC Comment Letter to CSA on Access-Based Model for Investment Fund Reporting Issuers

Key Recommendations Give Issuers the option to continue to use the current process, or adopt a true access-based systemIssuers should have the option to continue to use the current process, namely mailing annual reminders of the availability of the documents … Continue reading

December 22, 2022

PMAC Comment Letter to OSC on Statement of Priorities For Financial Year to End 2024

OSC Goals & PMAC’s Top Advocacy Requests PMAC is supportive of the four overarching goals set out in the Statement of Priorities, as well the work plans set out in support of those goals. We are pleased to have the … Continue reading

September 13, 2022

PMAC Comment Letter to CSA on National Instrument 43-101 Consultation

Important Context and Background PMAC’s members are fiduciaries entrusted to manage their clients’ assets in the clients’ best interests. As asset managers, our members are supportive of processes that increase transparency and that provide readily comparable information to assist them … Continue reading

August 31, 2022

PMAC Comment Letter to CAPSA on Guideline No. 3

Key Recommendations Provide additional information on the policy reasons for the updates to the Guideline, clarification of certain changes, and harmonize terminology with securities legislation. Create a separate Guideline for the decumulation aspects with additional guidance. Continue or expand existing … Continue reading

July 28, 2022

PMAC Comment Letter to CSA-CCIR Total Cost Reporting Joint Consultation

Key Recommendations Provide investors with total cost information. We believe that investors want to know three key pieces of information: (1) what their investments are worth today; (2) how much their value increased (or decreased) over time; and (3) how … Continue reading

June 28, 2022

PMAC Comment Letter to CSA on Application for Recognition of New SRO

Key Recommendation With respect to the Application for recognition of the New SRO, and Draft By-Law No. 1 in particular, we are generally pleased with the proposed governance and oversight reforms. It is clear that the CSA took stakeholder feedback … Continue reading

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