The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit comments regarding CSA Notice and Request for Comment Proposed Amendments to National Instrument 45-106 Prospectus Exemptions relating to Reports of Exempt Distributions (the “Proposed Amendments” or “Proposed Report”).
PMAC supports the efforts of the Canadian Securities Administrators (“CSA”) to reduce the compliance burden for issuers and underwriters under the exempt distribution reporting regime as evidenced by the welcome changes included in the Proposed Amendments. As stated in our submission dated May 28, 2014 in response to the CSA’s February 2014 Proposals, one set of harmonized reporting forms for all market participants available to all jurisdictions would eliminate the current and ongoing administrative confusion and complexity in meeting exempt distribution reporting requirements. Similarly, in our submission dated June 18, 2014 in response to the CSA’s March 2014 Proposals, we opposed the introduction of Form 45-106F10 Report of Exempt Distribution for Investment Fund Issuers (Alberta, New Brunswick, Ontario and Saskatchewan) which would have resulted in three different forms for reporting exempt distributions. PMAC is pleased that the Proposed Report addresses our concerns and the concerns of the industry generally.