The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation and Tax Committee, is pleased to have the opportunity to submit the following comments regarding the Proposed Amendments to National Instrument 31-103 Registration Requirements and Exemptions (“NI 31-103”) and to Companion Policy 31-301 Registration Requirement and Exemptions regarding the proposal that would require all registered dealers and registered advisers outside of Québec to utilize the Ombudsman for Banking Services and Investments (OBSI) as a service provider in respect of their dispute resolution or mediation services obligations under section 13.16 [dispute resolution service] of NI 31-103 (the “OBSI Proposal”).
