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September 2026 Advocacy Newsletter

Summary:

As the fall settles in, our docket is a full one. We’re preparing six responsive comment letters over the coming weeks and months, and while each responds to a specific proposal, together they speak to the questions we’ve been raising in recent commentary about coordination, modernization, and competition. These all point at whether Canadian capital markets adequately serve Canada’s economic needs, and capture our potential. We’re also proactively working on structural challenges relating to cybersecurity, finfluencers and their increasingly problematic collisions with market-side developments in expanded trading and prediction markets (among others), and the incentives and results of growing retail access to private markets. 

Several of this season’s consultations go directly to capital formation. The CSA’s proposal to make the higher limits under the listed issuer financing exemption permanent, and its broader consultation paper on modernizing the regulation of public companies, are welcome openings to rethink proportionate regulation for smaller issuers, particularly as the U.S. moves to reshape (lobotomize?) its own reporting and capital-raising rules. We’ll be encouraging the CSA to be thoughtful and ambitious here (incrementalism is a luxury Canada’s public markets can’t afford), but also to consider the broader issues of racing U.S. regulation to an evasive bottom that is neither to Canada’s benefit, nor in the public interest in our view. Others go to how the system serves investors day to day: CIRO’s proposals to speed up account transfers between firms and to give every advisor the option to incorporate both bear on investor choice, competition, and the structure of advice in Canada. 

Harmonization remains a through-line. Manitoba’s proposal to adopt the multilateral benchmarks regime closes a long-standing gap with the rest of the country. We’ll be commending the MSC for it, and encouraging it to help lead on turning other multilateral instruments into truly national ones. Coming on the heels of Ontario’s commitment to join the passport system, it’s further evidence that practical, cooperative steps toward a more integrated national market and a national regulatory system are within reach. 

And on the CSA’s proposed national instrument for the IT systems behind our market infrastructure, a proactive priority for the Canadian Advocacy Council, we’ll be making the case that resilient, modern market technology is foundational to market integrity and investor confidence, but that structural solutions might only be possible through changed, coordinative, and utility-driven approaches.

Our focus remains clear: a more coordinated, technologically modern, and globally competitive Canadian investment ecosystem that serves investors and supports the capital formation our economy needs.

Michael Thom, CFA

Managing Director

CFA Societies Canada