It is not necessary to introduce another exemption that is based on the purchaser’s relationship with an issuer; the private exemption, together with the family exemption reference below, would be sufficient. We believe it is important that to the extent possible the raising exemptions be harmonized across all Canadian jurisdictions.
Overview of the Council’s Comments:
We do not believe there are any additional prospective us exemptions that the OSC should consider. The existing prospectus exemptions, together with the proposed harmonized family member and offering memorandum exemptions, should provide SMEs with ample opportunities for fundraising while balancing investor protection considerations.