Proposed NI 31-103, Registration Requirements

June 20, 2007

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Proposed NI 31-103, Registration Requirements

Letter Summary:

The Canadian Advocacy Council (CAC) agrees with the broad objectives and principles of the proposal, although, we would like to comment in respect of some aspects which seem difficult or prohibitively expensive to comply with.

Overview of the Council’s Comments:

We hope the CSA will take our comments into consideration and review the proposal for NI 31-103. These proposed new rules will have a significant impact and we do not believe that, in their current form, these CSA rules and policies are achieving the goals originally set forth.