General Order 42-925 Saskatchewan Equity Crowdfunding Exemption (the “General Order”)

November 5, 2013

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General Order 42-925 Saskatchewan Equity Crowdfunding Exemption (the “General Order”)

Letter Summary:

As a general comment, the CAC is supportive of the efforts of the Saskatchewan Financial and Consumer Affairs Authority to proactively and quickly examine alternatives to the existing prospectus exemption regime. However, it is important that
the conditions of the proposed crowdfunding exemption do not favour small issuers over investor protection and transparency in the capital markets. We have a number of investor protection concerns with respect to the use of crowdfunding that can only be
addressed through strict monitoring and enforcement of the use of the exemption.

Overview of the Council’s Comments:

We believe it is important that, to the extent possible, the capital raising exemptions be harmonized across all Canadian jurisdictions. Harmonizing the exemptions would simplify the capital raising process for issuers, and would help issuers and prospective investors more easily confirm eligibility for participation in an exempt offering that occurs in more than one jurisdiction. Rather than instituting a crowdfunding exemption on a jurisdiction by jurisdiction basis, we believe it would be more advantageous to go forward with an exemption on the same terms as those agreed to in other CSA jurisdictions. As the exemption is intended to be available to raise only a small amount of capital, it would not seem economically feasible for issuers to raise capital based on this exemption if the terms were different in various Canadian jurisdictions.