The Portfolio Management Association of Canada (PMAC) was pleased to have the opportunity to submit the following comments regarding CSA Consultation Paper 51-405 – Consideration of an Access Equals Delivery Model for Non-Investment Fund Reporting Issuers (the Consultation).
PMAC represents over 285 investment management firms registered to do business in Canada as portfolio managers. PMAC’s members encompass both large and small firms managing total assets in excess of $2.8 trillion for institutional and private client portfolios.
- Although the Consultation is limited to non-investment fund reporting issuers, we encourage the CSA to also consider whether an access equals delivery model would be appropriate for investment fund issuers. We are in favour of access equals delivery for most investment fund continuous disclosure requirements, including for ETF issuers. This could be achieved through access to a designated website for investment fund issuers. We are of the view that the CSA should seize this opportunity to consider an access equals delivery model for investment fund issuers at the same time as the Consultation , as similar burden reduction and investor protection issues are involved and this would render the consultation process more efficient.
- We agree that using information technology can improve communication with investors, and is a more cost-efficient, timely and environmentally friendly manner of communicating information, compared to physical delivery of documents. Communication by electronic means may also be more effective and engaging for investors.
The full submission can be read here.