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 of the CMMT Consultation Report (Report).
PMAC represents over 285 investment management firms registered to do business with the various members of the Canadian Securities Administrators (CSA) as portfolio managers (PMs). Approximately 65% of our members are also registered as investment fund managers (IFMs). Close to 70% of our member firms are principally regulated in Ontario and almost all members do business in the province.
PMAC’s membership is comprised of firms of varying sizes and models, ranging from one-person firms to international and bank-owned firms. In total, our members manage in excess of $2.9 trillion of assets under management for institutional and private client portfolios. Our members also range from the more traditional model to online advisers.
PMAC’s mission statement is “advancing standards”. We are consistently supportive of measures that elevate standards in the industry, enhance transparency, improve investor protection and benefit our capital markets as a whole. Registered PMs have discretionary authority over investments they manage for their clients and have a duty to act in the best interests of their clients, also referred to as the fiduciary duty. PMAC strongly believes that this fiduciary duty is of utmost importance to investors, that its existence increases confidence in the capital markets and that it informs the way that PM firms operate their business and service their clients.
Throughout our submission, we will draw attention to the ways in which PM firms are unique from other registrant categories and we urge the CMMT to take these unique features into account when making recommendations to the Government of Ontario with respect to modernizing the province’s capital markets and securities law framework. We believe that a failure to do so could result in inappropriately prescriptive regulation that impinges on a PM’s professional judgement, hampers competition and innovation and, over the long term, does not benefit investors.
The official submission can be viewed in full here.