OVERVIEW

The Portfolio Management Association of Canada (PMAC), through our Industry Regulation & Taxation Committee, is pleased to have the opportunity to submit the following comments regarding the CSA’s Notice and Third Request for Comment – Proposed National Instrument 93-101 – Derivatives Business Conduct (Proposed NI 93-101) and Proposed Companion Policy 93-101 – Derivatives Business Conduct (CP and collectively, the Consultation).

PMAC represents over 300 investment management firms registered to do business in Canada as portfolio managers (PMs) with the members of the Canadian Securities Administrators (CSA). In addition to this primary registration, 70% of our members are also registered as investment fund managers and/or exempt market dealers. Some member firms manage large mutual funds or pooled products, and others manage separately managed accounts on behalf of private clients or institutions such as pension plans and foundations. PMAC’s members encompass both large and small firms and manage total assets in excess of $2.9 trillion.

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