Submissions to government

September 7th, 2021

PMAC Submission on Ontario Privacy Consultation

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). PMAC has been supportive of proposals that provide assurances to individuals that their privacy … Continue reading

August 26th, 2021

PMAC submissions to Canada Revenue Agency (CRA) on draft revised Guidance for FATCA and CRS

PMAC responded to the CRA’s consultation draft revised guidance with respect to FATCA and CRS. Read the submission on CRS here and on FATCA here.

August 16th, 2021

PMAC Submission – IOSCO Consultation Report: Recommendations for Sustainability-Related Practices, Policies, Procedures and Disclosures in Asset Management

Overview The Portfolio Management Association of Canada (PMAC), with the assistance of a member working group consisting of CFAs and ESG experts, is pleased to have the opportunity to submit the following comments regarding the International Organization of Securities Commissions … Continue reading

August 4th, 2021

PMAC Submission – Special Committee to Review the Personal Information Protection Act

The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to respond to British Columbia’s (BC) request for comments on modernizing the Personal Information Protection Act (Consultation). PMAC is supportive of BC’s efforts to enhance British Columbians’ individual … Continue reading

August 4th, 2021

PMAC Submission on Relief to Foreign Financial Service Providers

Overview The Portfolio Management Association of Canada (PMAC), through its International Committee, is pleased to have the opportunity to respond to the request for comment regarding the Relief to Foreign Financial Service Providers Consultation Paper (the Consultation) issued by the … Continue reading

July 27th, 2021

PMAC Comments on Proposed British Columbia Instrument 51-519 Promotional Activity Disclosure Requirements.

Overview PMAC agrees that any form of market manipulation or investor deception must be deterred and appropriately punished. We are generally of the view that regulation should be focused on specific behaviours and desired outcomes. We believe that the Consultation … Continue reading

July 15th, 2021

PMAC Submission – Exposure Draft – CFA Institute ESG Disclosure Standards for Investment Products

Overview The Portfolio Management Association of Canada (PMAC), through a working group consisting of CFAs and ESG experts and through its wider Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding the … Continue reading

July 5th, 2021

PMAC Submission on FSRA Financial Planner and Financial Advisor Rule and Guidance 2021

Overview The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to respond to the request for comment from the Financial Services Regulatory Authority of Ontario (FSRA) regarding its updated … Continue reading

June 11th, 2021

PMAC Comment on Saskatchewan FCAA Pension Solvency Funding Review

Overview PMAC is supportive of the FCAA’s goal of seeking stakeholder feedback on options to amend the solvency funding framework for single employer private sector pension plans (SEPPPs) under The Pension Benefits Act, 1992 (Act) and the Pension Benefits Regulations, … Continue reading

May 5th, 2021

PMAC Submission – CSA on Proposed Amendments to NI 33-109 – modernizing registration information requirements, clarifying outside activity reporting and updating filing deadlines

Background The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to respond to CSA Notice and Request for Comment on Proposed Amendments to National Instrument 33-109 – Registration Information (NI 33-109) and Changes to Companion Policy … Continue reading

March 18th, 2021

PMAC Submission – CSA Consultation Paper 25-403 – Activist Short Selling

OVERVIEW PMAC generally favours principles-based regulation that recognizes differences in business models, sizes, and client types. We support the CSA’s decision to consult with stakeholders on the important issues raised in the Consultation. Given the fast pace of change in … Continue reading

March 12th, 2021

PMAC Comment on Bill C-11, Digital Charter Implementation Act 2020

OVERVIEW PMAC’s mission statement is “advancing standards”; we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). Portfolio managers have a fiduciary duty to act with care, honestly and in good … Continue reading