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Letter Summary:
We support the enhanced clarity that will be provided by the Proposed Regulation which will set out the conditions for a prospectus exemption for the distribution of real estate investment contracts, as well as both a prospectus and registration exemption for the distribution of a security giving a right of exclusive use in an immovable. In particular the information in the proposed policy statement with respect to factors available to guide market participants as to the meaning of an “investment contract” is a very helpful explanation.
Overview of the Council’s Comments:
We thank you for the opportunity to provide these comments. We would be happy to address any questions you may have or to meet with you to discuss these and related issues in greater detail. We appreciate the time you are taking to consider our points of view. Please feel free to contact us at chair@cfaadvocacy.ca on this or any other issue in future.