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 to Required Insider Reports (the “Reports”). Capitalized terms used in this letter but not defined here have the same meaning given to them in the Consultation.
PMAC thanks the Exchanges for considering and raising the feedback they received with respect to the Reports to the Securities Regulators and for engaging in this public consultation on the continued utility of the Reports, concerns raised and potential solutions to these concerns.
Overview
PMAC represents investment management firms registered to do business in Canada as portfolio managers. PMAC members encompass both large and small firms managing total assets in excess of $1.5 trillion for institutional and private client portfolios1. PMAC advocates for the highest standard of unbiased portfolio management in the interest of the investors served by our members.
PMAC members share the concerns noted by the Exchanges in the Request for Comments around the potential market integrity issues raised by the Reports. PMAC appreciates the Exchanges’ consultation around appropriate courses of action that could appropriately balance any public benefits derived from the Reports against potential harms to the integrity of the Canadian capital markets, to certain market participants and, ultimately, negative impacts on end investors.
PMAC supports measures that protect the integrity and transparency of the Canadian capital markets while ensuring that investor returns are protected from the risk of unnecessary erosion through increased market costs arising out of the manipulation of information in the Reports. This is especially true where alternative reporting methods may otherwise achieve the same policy objective.