What’s new with the CAC?

Advancing investor protection, industry professionalism, and market integrity across Canada, the CAC works to focus attention on pressing advocacy files dominating the regulatory agenda. Ensuring fair, equitable, and sustainable outcomes for stakeholders is more important than ever, and through our growing relationships with policymakers and regulators, we are working on several important initiatives. Below is a summary of two areas where we have recently provided comment letters to consultation processes. To see the comprehensive catalogue of our commentary letters, visit us online at cfacanada.org/advocacy.

Published Canadian Advocacy Council of CFA Societies Canada (the “CAC”) comment letters

CSSB – Consultation Paper on Canadian Sustainability Disclosure Standards (CSDS)

The CAC believes that any changes to the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards S1 and S2 should be additive and not subtractive from the established international baseline; i.e., the IFRS Sustainability Disclosure Standards should not be diluted. The Canadian Sustainability Standards Board (CSSB) should look to add additional standards and requirements where needed, but the CAC is strongly of the view that the CSSB should not delete or materially disharmonize through modification the requirements from the IFRS Sustainability Disclosure Standards in creating Canadian standards.

The CAC cautions against any further delays to the standards’ effective date, noting that these are voluntary standards until made mandatory by legislation and/or regulation, and should support those Canadian issuers that are ready and wish to lead in their publishing of sustainability disclosures consistent with the IFRS Sustainability Disclosure Standards.

CIRO Rule Consolidation Project – Phase 3 – Canadian Investment Regulatory Organization

The Canadian Investment Regulatory Organization (CIRO) published Phase 3 of its Rule Consolidation Project for comment. The Rule Consolidation Project will bring together the two rule sets currently applicable to investment dealers (Investment Dealer and Partially Consolidated Rules (IDPC Rules)), and Mutual Fund Dealers Rules (MFD Rules) into one set of rules applicable to both categories of CIRO Dealer Members going forward. The CAC is generally supportive of this phase of the proposals, noting its support for the harmonization and simplification of rules, as these promote compliance and clarity for the industry.

The CAC asked CIRO to clarify its position and plan relating to registrants’ permissible use of personal corporations to conduct non-registerable and registerable activities. It reiterated concerns regarding investor protection and its position that clarity should be sought from tax authorities before proceeding with any change initiative, given the significant costs for industry of making any change. Among other specific comments, it noted that, concerning settlement hearings, the CAC prefers the flexibility of the MFD Rules, which empower the hearing panel to determine in what circumstances a settlement hearing could be made public, as there may be sufficient public interest reasons in certain cases.

Have your say

If you would like to participate in advocacy activity related to these letters or future policy and regulatory initiatives, provide comments on ongoing initiatives, or learn more about volunteer opportunities in advocacy or as a part of the CAC, please contact cac@cfacanada.org.

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Who is the Canadian Advocacy Council?

The Canadian Advocacy Council (CAC) is a volunteer advocacy council of CFA Societies Canada, representing the twelve Canadian CFA Institute Member Societies and, ultimately, Canadian CFA Charterholders. The council includes investment professionals from across the country who review regulatory, legislative, and standard-setting developments affecting investors, investment professionals, and Canadian capital markets. The CAC strives to advance market integrity, transparency, and investor protection, and actively engages Canada’s securities regulators, self-regulatory organizations, industry associations, legislators, and other stakeholders through thoughtful leadership, direct engagement, and the publication of comment letters.