CSA Notice and Request for Comment-Proposed Amendments to National Instrument 45-106 Prospectus and Registration Exemptions Relating to the Accredited Investor and Minimum Amount Investment Prospectus Exemptions (the“Notice”)

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CSA Notice and Request for Comment-Proposed Amendments to National Instrument 45-106 Prospectus and Registration Exemptions Relating to the Accredited Investor and Minimum Amount Investment Prospectus Exemptions (the“Notice”)

Letter Summary:

The CAC agrees that the proposed additional information to be contained in the exempt trade report will be useful information for the regulators and should not be unduly burdensome for issuers to provide.

Overview of the Council’s Comments:

At a minimum, we would suggest that all of the above-proposed conditions should be required in order for CEDIFs to be exempted from the investment fund manager registration requirements. We would recommend that the limit per beneficial investor be tied to that investor’s net worth or net assets and should be imposed on the purchase of any CEDIF in a calendar year