The consultation includes a number of proposed changes to participation fees, activity fees, late fees and the introduction of annual CPI-based fee adjustments. While we support several aspects of the proposal, including reduced participation fees for smaller registrants and a more proportionate approach for entities requiring enhanced regulatory oversight, we have raised concerns regarding the cumulative impact of the proposed fee increases on registrants operating nationally.
Our key recommendations are that the OSC:
- Provide greater transparency regarding the drivers of increased regulatory costs and the measures being taken to improve operational efficiency.
- Reconsider the proposed participation fee increase for the largest registrants and adopt a more moderate or phased approach.
- Maintain the current Form 45-106F1 filing fee for registrants and their managed investment vehicles.
- Replace automatic CPI-based fee increases with a periodic review process supported by evidence and stakeholder consultation.
- Adopt a cumulative cap on late fees for firms with strong compliance histories.
- Continue working with other CSA jurisdictions to harmonize regulatory fee structures.
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