The Canadian Advocacy Council of CFA Institute Canadian Societies (CAC) is pleased to respond to the Request for Comments dated February 23, 2007, where the Canadian Securities Administrators (CSA) invited interested parties to submit comments on the Proposed NI 31-103, Registration Requirements. Our comments are formatted in general terms and then by addressing the specific questions outlined in the Request for Comments.
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.