Submissions to Government

PMAC Submission – OSC Notice 11-798 – Statement of Priorities


PMAC Submission – OSC Notice 11-798 – Statement of Priorities

OSC consultation on its Proposed Statement of Priorities for Fiscal Year 2024-2025

On November 16, 2023, the OSC published for a 30-day comment period its proposed Statement of Priorities for the Fiscal Year 2024-2025 (SoP) that provides a list of the OSC’s priorities and associated activities. The OSC will consider stakeholder comments and make any necessary revisions prior to finalizing and publishing its final statement of priorities within the Business Plan for the Fiscal Years Ending 2025-2027.

PMAC is generally supportive of the OSC key priorities described in the proposed SoP, as well as the work plans set out in support of the underlying goals. Generally speaking, PMAC is concerned that recent guidance is increasingly prescriptive, deviating from principles-based regulations that are scalable and adaptable to different firms’ business models and operations. PMAC made several recommendations, including the following:

  • PMAC members are concerned that the OSC and other CSA members have been taking a stricter approach to the registration requirements for Advising Representatives, in particular with respect to the Relevant Investment Management Experience (RIME) required for registration.
  • PMAC believes that in order for the OSC to continue to be a responsive regulator and to meet the objectives outlined in the new six-year strategic plan, a review of its talent acquisition and retention strategy should be considered. This review could include an analysis of the competitiveness of the compensation and benefits program and its effectiveness in attracting individuals with more diverse skills, knowledge, and industry experience, including individuals who have completed the CFA and worked in portfolio management firms.
  • Systems improvements could reduce friction, confusion, and unnecessary frustration, especially as it relates to NRD and SEDAR+ filings. With respect to SEDAR+, our members note problems with the user experience including onboarding and retrieval of company information.
  • In order to streamline compliance reviews and reduce regulatory burden, compliance review programs should be tailored to the specific type of business. The priorities described in the proposed SoP do not refer to any specific initiatives aimed at reducing the regulatory burden for small and mid-sized firms or new entrants to the market and do not reference specific desired investor protection outcomes to justify the additional burden.

Read the full submission here with a link to the document