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 11-777 Statement of Priorities – Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2018 (the “Statement of Priorities“).
As background, PMAC represents investment management firms registered to do business in Canada as portfolio managers. In addition to this primary registration, many members are dually registered as investment fund mangers and/or exempt market dealers. PMAC members encompass both large and small firms managing total assets in excess of $1.5 trillion for institutional and private client portfolios.
PMAC advocates for the highest standard of unbiased portfolio management in the interest of the investors served by our members. For this reason, we are consistently supportive of measures that elevate standards in the industry and improve investor protection. We applaud the efforts made by the Ontario Securities Commission (“OSC”) to date in this respect, as well as the principles set out in the Statement of Priorities.
PMAC considers its goals to be very closely aligned with the Statement of Priorities articulated by the OSC and we would like to take this opportunity to thank the OSC and its colleagues that form the Canadian Securities Administrators (“CSA”) for the opportunity to participate in various formal and informal consultations around issues of importance to our members and, ultimately, to Canadian investors. These discussions are critical to the on-going dialogue between regulators and industry and help to shape effective, relevant, informed and practical regulatory policy. Similarly, we commend the OSC for its outreach to registrants and reporting issuers to promote compliance and to discuss and seek feedback on new and ongoing initiatives.
PMAC continues to support and champion the efforts of the CSA to identify opportunities to promote investor protection and to improve the registrant regulatory framework. We believe that the registrant-investor relationship is of utmost importance and that an effective way to bolster and improve this relationship is to allow registrants to focus on regulatory compliance measures that are principles-based and which provide benefit to investors and to the Canadian capital markets. For this reason, we are particularly pleased to see the OSC’s initiative to consult on ways to reduce the regulatory burden while maintaining appropriate investor protections. We understand that the OSC will be publishing a targeted consultation around ways to reduce regulatory burden for registrants and PMAC looks forward to making a more detailed submission at that time. We have, however, outlined some of our key recommendations on this priority in this letter in the hope that these topics will be considered and included in the targeted consultation as suggested areas in which the OSC will consider alleviating the regulatory burden.
Our comments on certain of the Priorities are set out in detail below. Certain of our comments are a reiteration of submissions PMAC has recently made to the OSC and/or to the CSA. Where this is the case, we have either linked to or provided a copy of the relevant submission.