The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is making this submission to the Ontario Securities Commission (OSC) to assist in the formulation of priorities for the OSC’s regulatory burden reduction taskforce.
On behalf of PMAC’s 260+ investment management firms registered with the Canadian Securities Administrators (CSA) to do business in Canada as portfolio managers, we are providing the following feedback on registrant-specific regulatory burden. We believe this industry-informed perspective is valuable for the OSC to consider as part of your policy making.
Regulatory burden represents an existential concern for many of our member firms who collectively manage assets in excess of $1.8 trillion for private and institutional client portfolios. Ultimately, higher regulatory burden and compliance costs facing portfolio managers have a negative impact on their end investors as well as on the Canadian capital markets.
We applaud the OSC for recently taking a leadership role in exploring the opportunity for regulatory burden reduction. Your efforts to stem the negative impacts of this burden while maintaining high standards are both necessary and welcome. Please see the attached appendix containing our responses to the questions contained on the OSC’s web portal. We also refer the OSC to our letter submitted to Chair & CEO Maureen Jensen on December 22, 2018 as further information.