CSA – Notice and Request for Comment – Proposed Ammendments and Proposed Changes to Implement an Access-Based Model for Investment Fund Reporting Issuers

December 26, 2022

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CSA – Notice and Request for Comment – Proposed Ammendments and Proposed Changes to Implement an Access-Based Model for Investment Fund Reporting Issuers

Letter Summary:

The proposed amendments to various national instruments would provide an alternative for investment funds that are reporting issuers to delivering financial statements and management reports of fund performance to unitholders. The purpose of these changes is to modernize the method by which these documents are made available to investors and would replace delivery with a requirement to post the documents on a designated website, issue, file on SEDAR and post a news release announcing the availability of the documents, and a requirement to deliver the documents upon request or upon standing instructions. Reporting issuer funds would no longer have to send an annual reminder or annual notice to rely on standing instructions regarding the delivery of financial statements. Investors could still request or provide standing instructions to receive the documents in either paper or electronic format.

Overview of the Council’s Comments:

The Council is generally supportive of the proposed access-based model as an alternative to delivering financial statements and management reports of fund performance for investment fund reporting issuers. Nevertheless, we believe that investment fund investors should be alerted to the release and availability of designated documents either through periodic notices or through new functionality on SEDAR+.

Our key comments are summarized below:

In our view, retail investors are unlikely to monitor for news releases on the funds of interest or search the designated website frequently to be aware of the availability of new filings.