Submissions to Government

PMAC Comments on the Ontario Capital Markets Act Consultation Draft


The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide feedback to the Ministry of Finance (Ministry) on the Capital Markets Act Consultation (the Consultation). PMAC represents over 300 investment management firms registered to do business with the various members of the Canadian Securities Administrators (CSA) as portfolio managers (PMs). Approximately 70% of our members are also registered as investment fund managers (IFMs). Close to 70% of our member firms are principally regulated by the Ontario Securities Commission (OSC) and almost all members do business in Ontario.

PMAC’s membership is comprised of firms of varying sizes and models, ranging from one-person firms to international and bank-owned firms, including more traditional models and online advisers. In total, our members manage in excess of $2.9 trillion of assets under management for institutional and private client portfolios.

Portfolio Managers

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 Canadian capital markets as a whole. Registered PMs have discretionary authority over investments they manage for their clients and have a duty to act in the best interests of their clients, also referred to as the fiduciary duty. PMAC strongly believes that this fiduciary duty is of utmost importance to investors, that its existence increases confidence in the capital markets and that it informs the way that PM firms operate their business and service their clients.


  1. Adopt platform legislation and continue to align regulation across the CSA jurisdictions. The OSC should be empowered to respond to the evolving capital markets landscape with necessary speed and flexibility. It is equally important that regulations maintain harmonization with existing National Instruments, as deviation represents a significant burden on firms and hinders competition.
  2. Maintain the minimum 90-day consultation period. The proposed 60-day comment period is not sufficient to conduct meaningful stakeholder consultation and obtain feedback.

Click here to view the full submission.