The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to provide written feedback to the Canadian Securities Administrators (CSA) on CSA Consultation Paper 25-402 Consultation on the Self-Regulatory Organization Framework (the Consultation). PMAC represents over 285investment management firms registered to do business with the various members of the CSA as portfolio managers (PMs). Approximately 65% of our members are also registered as investment fund managers (IFMs). PMAC’s membership is comprised of firms of varying sizes and models, ranging from one-person firms to international and bank-owned firms. In total, our members manage assets in excess of $2.9 trillion for institutional and private client portfolios. Our members also range from the more traditional models to online advisers.
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 our capital markets as a whole. We are also cognizant of the global market in which many of our mid-size and large members operate and are sensitive to any regulatory changes being misaligned with other international capital market jurisdictions.
This Consultation has generated discussion and debate among numerous stakeholders, which we view as a positive development. Some recent proposals, notably from the Capital Markets Modernization Taskforce (CMMT) and Mutual Fund Dealers Association (MFDA) contemplate the creation of a single self-regulatory organization (SRO) that covers all advisory firms, including PMs, exempt market dealers (EMDs) and scholarship plan dealers (SPDs). As we noted in our response to the CMMT, we believe that PMs, IFMs and EMDs should remain under the oversight of the CSA.
The full submission can be read in full here.