Multilateral CSA Notice Request for Comment – Proposed Amendments to National Instrument 13-101 System for Electronic Document Analysis and Retrieval (SEDAR) and Multilateral Instrument 13-102 System Fees for SEDAR and NRD (the “Proposed Amendments”)
We agree with the statements in the Proposed Amendments with respect to the benefits of the proposed filing requirements for issuers and investors. Given the costs of a public issuance of securities, more and more issuers are turning to the private markets for capital. The availability of information such as offering documents on a commonly used website will make it much faster and
easier to access information about private placements, and to the extent they are interested in doing so, potential investors will be able to compare and contrast various issuers in the same industry on a more efficient and transparent basis. While some sophisticated investors already know how to access copies of private placement form information (in various paper formats), improving the delivery mechanism by providing the information electronically may level the playing field among retail investors.
Overview of the Council’s Comments:
We agree with the steps that will be required to be followed with respect to removing the personal information in Schedule 1 of the exempt trading report prior to accepting the form on SEDAR. It is vital that the personal information of purchasers be protected. The acknowledgement by the filer should be clear (i.e. more than just a check the box; potentially requiring the filer to insert wording acknowledging that the information has been removed) in order to protect from accidental disclosure of a Schedule 1 on SEDAR.