The CAC favour neither an exclusively principles-based nor rules-based approach to securities regulation, including corporate governance requirements. We believe that even the most principles-based system requires prescriptive rules to provide contextual clarification for users of the system and that rules-based systems have to provide some broad principles for users to understand the contextual basis for the rules. Therefore, we believe that one of the most important components of the system is the breadth of the disclosure regime that is prescribed and the enforcement of this disclosure regime.
Overview of the Council’s Comments:
The Canadian Advocacy Council of CFA Institute Canadian Societies (CAC) is pleased to respond to the Request for Comments dated December 19, 2008 in which the Canadian Securities Administrators (CSA) invited interested parties to submit comments on the proposed Corporate Governance Framework.