The Portfolio Management Association of Canada (PMAC), through a working group consisting of CFAs and ESG experts and through its wider Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding the CFA Institute’s Consultation Paper on the Development of the CFA Institute ESG Disclosure Standards on Investment Products (the Consultation and the Standard, respectively).
PMAC represents over 280 investment management firms registered to do business in Canada as portfolio managers. Some firms manage large mutual funds or pooled products and others manage separately managed accounts on behalf of private clients or pension plans and foundations. In addition to this primary registration, most of our members are also registered as investment fund managers and/or exempt market dealers. PMAC’s members encompass both large and small firms managing total assets in excess of N $2.8 trillion for institutional and private client portfolios.
The following context about PMAC’s members is important to our comments on this Consultation and will help inform the CFA Institute’s understanding of our perspective on the Standard. Our member firms range from asset managers that operate globally and are subject to a plurality of legal and regulatory requirements to smaller firms that operate solely within Canada.
PMAC’s mission statement is “advancing standards” and, as part of our effort to support that mission, upon applying for PMAC membership, we require all member firms to attest that: 1) they have adopted the CFA Institute Asset Manager Code of Professional Conduct; or 2) that the firm’s code of ethics/conduct complies with the six principles of conduct of the CFA Institute Asset Manager Code of Professional Conduct.
Additionally, in order to become registered as an advising representative (AR) or associate advising representative (AAR) with a portfolio management firm with the various members of the Canadian Securities Administrators (CSA), an individual must meet stringent proficiency requirements; one of two ways to meet these proficiency standards is by having the CFA Charter and 12 months of relevant industry experience (for ARs) or having Level 1 of the CFA and 24 months of relevant industry experience (for AARs). As such, the vast majority of our members’ individual registrants hold a CFA Charter.
The full submission can be viewed in full here.