Submissions to Government

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


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 would better achieve its objectives through further tailoring and clarification, as discussed in detail below. As drafted, we are concerned that the proposed rules are ambiguous and overly broad. As a result, they risk being less effective and open to challenge on constitutional or other grounds.
PMAC generally favours principles-based regulation that recognizes differences in business models, sizes, and client types. We support the British Columbia Securities Commission’s (BCSC) decision to consult with stakeholders on the important issues raised in the Consultation. Given the fast pace of change in the industry, it is understandably difficult for regulation to predict or keep up with developments in the market and investor behaviour. For this reason, we believe it is important for regulatory bodies to hear from market participants in deciding whether regulatory intervention is required and if so, what form it should take.

Read the full submission here.