The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding OSC Notice 11-785 Statement of Priorities – Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2020 (the Statement of Priorities).
As background, PMAC represents 270 investment management firms registered to do business in Canada as portfolio managers. In addition to this primary registration, the majority of our members are also registered as investment fund mangers and/or exempt market dealers. PMAC’s members encompass both large and small firms managing total assets in excess of $2.1 trillion for institutional and private client portfolios.
PMAC is supportive of the four overarching goals set out in the Statement of Priorities and we are pleased to have the opportunity to provide the following feedback on certain aspects of them.
PMAC has made several recent submissions to the Ontario Securities Commission (OSC) and the Canadian Securities Administrators (CSA) on a range of advocacy issues impacting portfolio managers and their clients. In lieu of re-iterating our key recommendations on those issues in this submission, and in recognition of the diligence and consideration with which the OSC and CSA review stakeholder comments, we are instead setting out the following topics (along with submission links, where applicable), which highlight PMAC’s regulatory “wish list” for the year to come. We believe that these issues are very closely tied in several ways to the OSC’s goals, especially promoting confidence in Ontario’s capital markets, reducing regulatory burden, and facilitating financial innovation:
- Regulatory burden reduction;
- Client Focused Reforms;
- Registration of client relationship manager advising and associate advising representatives with terms & conditions; and
- Derivatives – Business Conduct and Registration.
We would also like to note our appreciation for the thoughtful and detailed dialogue that OSC Staff have engaged in with PMAC and our membership on the issues listed above.