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 Toward Their Clients (the “Consultation”). Capitalized terms used in this letter but not defined here have the same meaning given to them in the
Consultation.
PMAC thanks the CSA for the work done by its members to draft the Consultation and for the opportunity to participate in various discussions on the very important proposals in this Consultation.
Our response is primarily focused on the implications that the Consultation may have for firms and individuals registered as “portfolio managers” under National Instrument 31-103 – Registration Requirements and Exemptions (“NI 31-103”), however, we have also commented on certain other matters of significance affecting other registration categories.