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December 2024 Advocacy Newsletter

Summary:

Over the past year, CAC has submitted comment letters on a wide range of high-profile issues. We engaged in continued advocacy for empowering the Ombudsman for Banking Services and Investments as an accessible, binding dispute resolution regime for retail investors, and for the adoption of Canadian Sustainability Disclosure Standards for public issuers.

We also asked regulators to think bigger when it came to designing meaningful options for redistributing disgorged funds to harmed investors. And we offered feedback on the Canadian Investment Regulatory Organization’s ongoing efforts to consolidate its rulebook, including by flagging potential perverse consequences from their proposal to let more advising representatives divert their compensation into personal corporations.

At several points this year, we asked regulators to be clearer about the evidence and value judgments that underlie their proposals—without this background, it’s sometimes difficult for us to offer meaningful feedback. The two comment letters we submitted this month, on the Ontario Securities Commission’s annual statement of priorities and proposed changes to the mandatory central counterparty clearing regime for derivatives, drive these points home.

In 2025, we look forward to participating in even more conversations about the future direction of securities and broader financial regulation. Until then, Happy Holidays!