While we believe that each of the New York Stock Exchange, NYST MKT, NASDAQ, London Stock Exchange Main Board, AIM, Australian Securities Exchange and Hong Kong Stock Exchange Main Board have rules that are transparent and provide
sufficient regulatory oversight, we would prefer that additional exchanges not be automatically considered a “Recognized Exchange” without a new public comment process and an opportunity for review by the applicable securities regulatory authorities. We consider a rigorous review process of corporate transactions by an exchange to be important to the integrity of the capital markets, particularly with respect to foreign issuers that may not have many other connections to Canada, and thus it is important that the market is comfortable with the exchanges to which the TSX can essentially delegate its supervision.
Overview of the Council’s Comments:
As a general comment, the CAC supports efforts to improve the ease with which issuers can raise capital in Canada and operate efficiently while balancing investor protection considerations. We also support greater transparency for issuers and the general public with respect to the availability of exemptions from the requirements contained in the Company Manual. We wish to respond to your specific inquiry regarding the appropriateness of the definition of a “Recognized Exchange”.