CSA NI 31-103 Custody – EMD proposals

September 26, 2016

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CSA NI 31-103 Custody – EMD proposals

Letter Summary:

We are supportive of the proposed clarifications to the permitted activities for exempt market dealers, in that the Proposed Amendments should result in a consistent application of the principle that EMDs should not participate in offerings of securities under a prospectus in any capacity. The new proposed guidance in 31-103CP is particularly helpful with respect to investment fund securities, where it is specifically noted that exempt market dealers may trade in such securities provided they are distributed under prospectus exemption. We agree that freely tradeable securities should only be traded by investment dealers subject to the oversight of IIROC and subject to the universal market integrity rules.

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.