PMAC responded to the OSC’s Statement of Priorities for 2026-27. Our key recommendations are for the OSC to:
- Join the CSA passport system; and
- Refrain from delegating any further registration responsibilities to the Canadian Investment Regulatory Organization (CIRO).
In our view, OSC participation in the CSA passport system for registration, prospectus review, and exemptive relief represents the single most effective step the OSC could take to achieve greater harmonization within Canada’s securities regulatory framework, to enhance collaboration among CSA members and reduce regulatory burden for registrants. This would also contribute to the provincial and federal governments’ goals of improving inter-provincial trade and removing barriers in order to boost the productivity, efficiency and competitiveness of Canada’s markets.
PMAC strongly opposes the proposed delegation of additional registration responsibilities to CIRO. It is not clear which responsibilities will be delegated, but we understand that registration of additional categories of registrants (including portfolio managers and exempt market dealers) is intended. While framed in the Statement of Priorities as an efficiency-oriented modernization initiative, this proposal would in fact constitute a fundamental and high-risk restructuring of the regulatory framework governing fiduciary asset managers. We have included a detailed appendix in our letter setting out our position on this proposed delegation.
The balance of our comments on the Statement of Priorities are focused on modernization and burden reduction measures, including making regulation evidence-based and proportionate, treating institutional investors differently from retail investors, improving registration processes and service standards, considering whether PMs need EMD registration, changing Form 45-106F1 filing requirements, and adopting access-based continuous disclosure for investment funds.
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