The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments IIROC’s Notice on Proposed Amendments to Client Identification and Verification Requirements (the “Proposed Amendments”). Capitalized terms used in this letter but not defined here have the same meaning given to them in the Proposed Amendments.
Overview
PMAC represents investment management firms registered with the Canadian Securities Administrators (the “CSA”) to do business in Canada as portfolio managers. 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. While PMAC’s advocacy efforts are typically focused on CSA initiatives as well as Federal and Provincial matters directly impacting our membership, we are providing comments on the Proposed Amendments since our members and the investors they serve could be negatively and directly impacted.