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Proposed Amendments to NI 51-102 Continuous Disclosure Obligations
Letter Summary:
The CAC represents the 13,000Canadian members of CFA Institute1 and its 12 Member Societies across Canada. The CAC membership includes portfolio managers, analysts and other investment professionals in Canada who review regulatory, legislative, and standard setting developments affecting investors, investment professionals, and the capital markets in Canada.
Overview of the Council’s Comments:
The CAC believes that required MD&A disclosure rules should include further information on an issuers’ current debt ratios included within credit agreements and trust indentures. Specifically, the CAC suggests including a table with 1) all significant debt covenants ratios; 2) the level that must be maintained according the various debt indentures, and 3) the current level of the ratio as of the reporting date. Disclosure should apply both for public debt and private debt (including private placements and bank debt).