The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to participate in the consultation process regarding the proposed amendments to NI 31-103 (the “Amendments”).
PMAC supports amendments that represent general improvements to the registrant regulatory framework. We agree that periodic improvements should be made that reflect the realities of the Canadian markets and the evolution of the registrant landscape post the 2009 implementation of NI 31-103. The comments included in this submission primarily focus on the Amendments which directly impact portfolio managers.
We believe certain areas continue to require further work, clarification and modification. For instance, we note that the CSA have proposed rule changes that will narrow the permitted activities to be conducted by dealers registered in the category of exempt market dealer (EMD). We will not be providing substantive comments on this proposed amendment however; we believe the CSA needs to carefully consider the scope of the limitations included in the Amendments as relative to the impact on this segment of the market and that further consultation is required in this area.