OSC – Notice 11-797- Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2024

December 22, 2022

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OSC – Notice 11-797- Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2024

Letter Summary:

The draft Statement of Priorities is similar to prior years and sets out four goals: Building Trust and Fairness in Ontario’s Capital Markets, Strengthening Investor Safeguards, Adapting Regulation to Align with Innovation and Evolving Markets, and Enabling the OSC to Deliver Effective Regulation. It includes a number of key priorities within these goals, including advancing work on ESG issues for reporting issuers, considering broader diversity on boards and in executive roles at reporting issuers, and incorporating Indigenous People’s issues and perspectives into CSA policy work. Other significant priorities include the total cost reporting amendments, the derivatives business conduct rules, and a potential framework for investment funds when investing in crypto assets.

Overview of the Council’s Comments:

The Consultation includes many laudable priorities. But in the Council’s view, without more background from the OSC on how its proposed priorities connect to its expanded mandate and more substantive target outcomes and related KPIs, it is difficult for stakeholders to meaningfully engage in this process.

Key comments are summarized below:

With respect to ESG-related investment fund disclosures, we remain concerned that without additional rulemaking, problematic marketing practices may impair investor confidence.