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 three areas where we have recently provided comment letters to consultation processes. To see the comprehensive catalogue of our commentary letters, visit us online a cfacanada.org/advocacy.

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

CSA – Proposed Amendments to Form 58-101F1 Corporate Governance Disclosure of National Instrument 58-101 Disclosure of Corporate Governance Practices and Proposed Changes to National Policy 58-201 Corporate Governance Guidelines

For the reasons outlined in the comment letter, the CAC supports adopting the more prescriptive Form B approach to diversity disclosure set out in the Consultation. We would prefer this to include a requirement to disclose diversity considerations concerning executive officer appointments and approaches to talent management for executive officers.

Standardized, decision-relevant disclosure gives issuers room to provide additional context and facilitates informed voting and other investment decisions. Non-standardized disclosure requires investors to piece together what relevant information issuers’ management teams might or might not be offering. If the CSA cannot agree on this approach, the CAC would support a decision by the Ontario Securities Commission to adopt Form B unilaterally.

CPAB – Request for Comment on the Canadian Public Accountability Board’s Proposed Rule Changes

The Canadian Public Accountability Board (CPAB) launched a public consultation to gather feedback on proposed changes to the information disclosure rule. The CAC strongly supports the changes in the Proposal aimed at increasing regulatory transparency concerning issues found in CPAB’s review of audits conducted by participating audit firms. Integrity and reliability of audits are foundational to the ethical rigour, transparency, and confidence in Canadian capital markets. Information relevant to the work of audit firms trusted with reviewing the financial statements of Canadian public issuers is of great interest to the governing bodies of those issuers, their shareholders, and, more widely, to various stakeholders in Canada. Ensuring the integrity, consistency, and aptitude of the firms conducting those audits and the audits themselves is, therefore, of the utmost importance.

CSA – Notice and Request for Comment – Proposed Amendments to National Instrument 44-102 Shelf Distributions Relating to Well-known Seasoned Issuers

The Canadian Securities Administrators (CSA) is seeking public comment on a proposed expedited shelf prospectus regime for well-known seasoned issuers (WKSIs) in Canada. The proposed amendments are intended to foster capital-raising by WKSIs in the Canadian public markets.

The CAC is in broad agreement with the proposed WKSI regime and believes the availability of this option will likely result in more cost-efficient capital raises for eligible large issuers without introducing material new risks to investors or the integrity of capital markets.

We believe that the adoption of a WKSI regime in Canada as set out in the Proposal is a positive step for Canada’s capital markets, which will reduce the regulatory burden for well-established, mature, and closely followed reporting issuers, and will contribute to more efficient capital formation in the Canadian marketplace.

Other letters filed:

• Manitoba Finance – Financial Planner Title Protection in Manitoba
• OSC Notice 11-798 – Statement of Priorities – Request for Comments Regarding Statement of Priorities for Fiscal Year 2024-2025
• CIRO Bulletin 23-0147 – Rules Bulletin – Request for Comments – DC Rules – Rule Consolidation Project – Phase 1

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.