OSC Staff Notice 11-784 Burden Reduction Survey

March 1, 2019

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OSC Staff Notice 11-784 Burden Reduction Survey

Letter Summary:

The OSC is looking for ways to reduce unnecessary regulatory burden, with a focus on (1) Operational and procedural changes. In particular, identifying changes to make day-to-day interactions with the OSC easier, less costly and provide certainty regarding regulatory requirements and outcomes. (2) Rule changes with a focus on identifying rules that are inconsistent with the rules of other jurisdictions and specific requirements that no longer serve a valid purpose. (3) Enhancing and improving investor experience with the disclosure provided to them, for example, by promoting plain language disclosure.

Overview of the Council’s Comments:

The council applauded the OSC’s intention and efforts to reduce regulatory burden and the willingness to seek feedback. In its survey response, the CAC provided targeted recommendations in the three areas in question. In summary, the council suggested the OSC work in tandem with other CSA jurisdiction to reduce regulatory burdens. For example, removing duplicative disclosure requirements in fund prospectus and fund facts documents. The council also suggested a more data driven approach to suggesting new regulations to help articulate how new regulations will improve outcomes. A transparent risk-based approach to targeting deficient registrants. The council suggested more technology oriented solutions to improve interaction, transparency and engagement between investors and market participants and regulators. The council also recommended a mechanism for regulated firms to escalate compliance review disagreements and ask questions about regulatory expectations and seek regulatory feedback.