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Multilateral CSA Notice of Publication and Request for Comment
Letter Summary:
The proposed requirements for registered portals and the caps on investment are important safeguards, but additional restrictions could be considered specifically to address concerns relating to investors with low financial literacy and/ or minimal investment men experience. Timely and effective enforcement will also be key to mitigating the risk of abuse and fraud. Staff should monitor, in particular, that the requisite financial reports are provided in a timely fashion and completed as required.
Overview of the Council’s Comments:
With respect to disclosure requirements, unique obligations may be required in order to provide investors with tangible, relevant information on the issuer without requiring the issuer in all cases to provide expensive, audited financial statements. For example, the issuer could be required to post-tax returns or assessments (redacted as needed to protect confidential information) as a method of confirming revenue (or the lack thereof).