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November 2025 Advocacy Newsletter

Summary:

As we close out November, our advocacy work has been centered on the health and vitality of the Canadian investment ecosystem and the case for entrepreneurship in asset management both with government and regulators, centered on ensuring that Canada’s policy and regulatory environment supports growth, competitiveness, clarity and innovation across the investment ecosystem. As we’ve written previously, we were delighted by the Government of Canada’s nod in Budget 2025 to the contributions to economic development by the asset management sector, and the need to support emerging fund managers to build the next generation of global-champion businesses in Canada.

We are using this recognition to power our continued efforts advocating for entrepreneurship, competition, and innovation with multiple governments and regulators across Canada in partnership with our peer organizations in the Canadian Asset Management Entrepreneurship Alliance. We continue to advocate that Canada needs to urgently chart its own course for the investment and financial services sector within the context of renewed concerns about economic sovereignty, and the government’s many identified needs for capital deployment and investment at-scale – where our profession and industry is a necessary partner. We remain concerned (and vocal) that our lack of interprovincial regulatory harmonization will make it difficult to be as dynamic and responsive in Canada as some of these changes abroad should demand, and that our regulatory structures that focus on process perhaps over outcomes don’t serve this moment. We need to work harder to meet this moment by being dynamic, harmonized, and ambitious.

This month, the Canadian Advocacy Council provided detailed feedback to the Ontario Securities Commission on its Draft Action Plan for Truth and Reconciliation, highlighting the importance of leadership accountability, Indigenous representation and the integration of Indigenous investors into policy considerations. The Council also responded to CIRO’s proposed updates for Order Execution Only accounts, emphasizing stronger safeguards, clearer expectations and a more agile, principles-based approach. Looking ahead, our focus shifts to several in-progress responses, including the CSA consultations on venture issuer semi-annual reporting and the proposed harmonized self-certified investor exemption, along with CIPC’s work on the Exposure Draft for best practices in return attribution reporting.

We continue to prepare for the implementation of CIRO’s new proficiency model, which takes effect on January 1 and includes significant positive changes to exam exemptions for CFA Program candidates and CFA charterholders. CFA charterholders or recent passers of the Level 1 exam will be able to avail themselves of an exemption for the new introductory CSIE exam, and either of the new qualifying ‘segment’ exams – Retail or Institutional. This process runs through the CIRO dealer member firm at the time of registration, so there’s no action to take on an individual level to qualify or apply. Please see CIRO’s proficiency website for more details on the new model, and this link for a member and candidate-focused FAQ from CFA Institute.

We also encourage you to explore the findings of our inaugural Annual Canadian Endowment and Foundation Survey (see below) – in collaboration with Mercer Canada, which offers new and unique insights for Canadian not-for-profit investing organizations and their advisors and partners.

As we head into the end of the year, both our proactive outreach agenda and responsive commentary plates are full, and we are looking forward to reviewing the imminent decision from the Supreme Court of Canada in Lundin v. Markowich – where we’ll have more to say soon.

Thank you for your continued engagement with our policy and standards work as we advance a more coordinated, ambitious, and forward-looking vision for Canadian capital markets.

Michael Thom, CFA

Managing Director

CFA Societies Canada