Submissions to Government

PMAC Comment – CSA Position Paper 25-404 New Self-Regulatory Organization Framework


The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Canadian Securities Administrators (CSA) on CSA Position Paper 25-404 – New Self-Regulatory Organization Framework (the Position Paper). PMAC represents over 300 investment management firms registered to do business with the various members of the CSA as portfolio managers (PMs). Approximately 65% of our members are also registered as investment fund managers (IFMs). Our members manage assets in excess of $2.9 trillion for institutional and private client portfolios; they range in size from one-person firms to large and bank-owned institutions, include traditional and online advisers, and operate domestically and internationally.

PMAC’s mission statement is “advancing standards”. We are consistently supportive of measures that elevate standards in the industry, enhance transparency, improve investor protection, and benefit our capital markets. We are also cognizant of the global market in which many of our mid-size and large members operate and are sensitive to any regulatory changes being misaligned with other international capital market jurisdictions.

PMAC takes no position on the decision to establish a new self-regulatory organization (SRO) to replace the Investment Industry Regulatory Organization of Canada (IIROC) and the Mutual Fund Dealers Association of Canada (MFDA), and to consolidate the two current investor protection funds (IPFs). We are strong supporters of good corporate governance and therefore have focused our recommendations on ways to strengthen CSA oversight of the new SRO and ensure the inherent conflicts of interest within an SRO structure are managed.

Read PMAC’s comments in full here