The Canadian Advocacy Council of CFA Institute Canadian Societies (CAC) is pleased to respond to the Request for Comments dated May 31, 2010 in which certain members of the Canadian Securities Administrators (CSA) invited interested parties to submit comments on a Consultation Paper concerning Tailoring Venture Issuer Regulation.
Overview of the Council’s Comments:
The CAC believes that facilitating access to the capital markets is in the public interest but that it is important to ensure that investor confidence and trust in the capital markets is maintained. We do not believe that the proposed changes will meet these criteria. The principles and guidance found within the CFA Institute’s Code of Ethics and Standards of Professional Conduct require that our members should only invest once they have done proper due diligence with respect to investment recommendations. The proposed changes, due to their reduced disclosure requirements, will not provide sufficient information to permit a user to formulate an informed recommendation. Our comments to your specific questions appear in italics as follows.