Submissions to Government

PMAC Comment Letter on 2022 OSC Fees Consultation


The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding Proposed Amendments to OSC Rule 13-502 Fees, OSC Rule 13-503 (Commodity Futures Act) Fees and Proposed Changes to their Companion Policies (the Consultation).

PMAC represents over 300 investment management firms registered to do business in Canada as portfolio managers (PMs). In addition to this primary registration, the majority of our members are also registered as investment fund managers (IFMs) and/or exempt market dealers (EMDs). PMAC’s members encompass both large and small firms managing total assets in excess of $2.9 trillion for institutional and private client portfolios.

Support for Consultation

PMAC is very supportive of the Consultation – the proposed amendments to fees impacting asset managers are welcomed by our members We view the Consultation as an important component of the work being undertaken by the OSC to reduce regulatory burden and we are cognizant that both the participation and other fee reductions are being enabled in part by the introduction of the new derivatives participation fee that will impact certain larger registered firms.

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