The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Proposed Amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations, the Companion Policy to NI 31-103 (the “CP”), National Instrument 33-109 – Registration Information and Related Forms (the “Proposed Amendments”).
Capitalized terms used in this letter but not defined here have the same meaning given to them in the Proposed Amendments.
PMAC represents investment management firms registered to do business in Canada as portfolio managers. PMAC members encompass both large and small firms managing total assets in excess of $1.5 trillion for institutional and private client portfolios.
PMAC advocates for the highest standard of unbiased portfolio management in the interest of the investors served by our members and is appreciative of the efforts of the CSA to continue to refine the instruments underlying the client-registrant relationship.
PMAC is generally supportive of the Proposed Amendments as they are designed to improve investor protection and reduce intermediary risk through the Custody Amendments; to provide additional transparency and clarification of the CSA’s thinking around the appropriate use of the exempt market dealer (“EMD”) registration; and to codify and streamline CRM2 requirements.
PMAC members have raised certain questions and comments about various aspects of the Proposed Amendments and these are set out in further detail below.