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Letter Summary:
Proposed new National Instrument 13-103 would replace the current rules and framework for SEDAR, the National Cease Trade Order Database, the Disciplined List, SEDI, NRD and the National Registration Search in four phases beginning in early 2021. Phase 1 will focus on replacing SEDAR, the National Cease Trade Order Database, the Disciplined List and certain filings through the electronic portals in Ontario and B.C. made by issuers. Once fully implemented, the system would provide single-window access for market participants to file documents and pay fees.
Overview of the Council’s Comments:
The council is broadly supportive of the updates being made by the CSA to the CSA National Systems, including SEDAR. The council believes that is important that users of the information filed on the systems can find the continuous disclosure material quickly and without difficulty, as not every investor has access to subscription services that allow filed materials to be searched by topic and keywords.
With respect to SEDAR, our comment letter provides EDGAR as an example of a model to mirror. In the U.S., academic research has supported the use of data mining of issuer filings on EDGAR. The researchers conclude that historical EDGAR data is being extracted in a sophisticated manner. The council believes this model would provide additional benefits to the ongoing CSA burden reduction initiatives.