CFA Societies Canada Quarterly Update

What’s new with advocacy at CFA Societies Canada?

Advancing investor protection, industry professionalism, and market integrity across Canada, CFA Societies Canada focuses attention on pressing advocacy files dominating the regulatory agenda. Ensuring fair, equitable, and sustainable outcomes for stakeholders is more important than ever. 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 see the comprehensive catalogue of our commentary letters, visit us online at cfacanada.org/advocacy.

Published CFA Societies Canada comment letters

CSA – Financial Innovation Hub Introduces Collaboratory and Data Portability Test

On May 16, 2025, the Canadian Advocacy Council of CFA Societies Canada (CAC) submitted a comment letter to participating members of the Canadian Securities Administrators (CSA) in response to CSA Multilateral Discussion Paper 11-406 – CSA Financial Innovation Hub Introduces Collaboratory and Data Portability Test. The consultation sought input on potential regulatory and industry developments related to electronic know-your-client (e-KYC) systems and data portability frameworks.

In its submission, the CAC provided recommendations and considerations for implementing these innovations in the Canadian capital markets. The CAC acknowledged the potential benefits of modernization but emphasized the importance of regulatory clarity, standardization, and investor protection.

Highlights from the submission include that the CAC:

• Recognized barriers within current securities legislation, particularly the inability of registrants to delegate KYC responsibilities, and recommended revised or additional guidance to support reliance on e-KYC solutions while

safeguarding against improper use

• Supported the development of a centralized, standardized e-KYC utility system to promote consistency and reduce reliance on fragmented or proprietary solutions

• Stressed that without a harmonized, national approach, data portability initiatives could be limited by inconsistent

regulatory frameworks across jurisdictions

• Emphasized that an industry-wide standard for data portability would enhance transparency, efficiency, and competition, while also supporting innovation and investor control over personal information

• Encouraged the CSA to consider open-source collaboration models, such as those supported by the Fintech Open Source Foundation (FINOS), to build and maintain shared KYC platforms, standards, and utilities

• Highlighted the opportunity for the CSA to define a clear vision and minimum standards for KYC, which could improve regulatory certainty for registrants and benefit investors

CSA – Securities Regulatory Harmonization in Canada – Seizing the Moment (Joint PMAC & CFA Societies Canada Letter)

On April 14, 2025, CFA Societies Canada and the Portfolio Management Association of Canada jointly issued a letter to the Canadian Securities Administrators (CSA) urging renewed leadership to address persistent fragmentation in Canada’s securities regulation system.

Recognizing today’s pressing economic and geopolitical challenges, the letter called this a critical opportunity for Canada to pursue greater harmonization of its securities regulation, not through a grand legislative overhaul, but via concrete, actionable reforms that utilize existing collaboration frameworks and regulatory tools.

The letter proposes five potential strategic initiatives for immediate CSA action:

1. CSA Vision Statement on Harmonization
A call for the CSA to formally adopt harmonization as a core strategic priority, supported by measurable targets and transparent annual reporting on progress and challenges.

2. Enhanced Transparency

A proposed public-facing dashboard and searchable database to track and explain regulatory differences across jurisdictions, complemented by structured stakeholder feedback mechanisms.

3. Multilateral Instrument Transition Plan
A multi-year roadmap to convert Multilateral Instruments into National Instruments wherever feasible, supported by sunset clauses and criteria for divergence justification.

4. Systematic Review of Local Rules

The creation of a task force to review and recommend updates or retirements of Local Rules based on clear, consistent criteria, with publicly reported outcomes and milestones.

5. Model Regulation Development
Establishment of a working group to develop model regulations for areas where formal harmonization is impractical, encouraging voluntary alignment with tracked implementation.

CIRO – Rule Consolidation – Phase

The Canadian Advocacy Council (CAC) of CFA Societies Canada responded to Canadian Investment Regulatory Organization (CIRO) Bulletin 24-0276, commending CIRO’s progress on harmonizing regulatory requirements through its Phase 5 Rule Consolidation Project.

The CAC emphasized the importance of clear guidance and adequate transition periods to support effective implementation and maintenance of investor protection.

Highlights from the CAC’s submission include that the CAC:

• Supported including prospective clients in the definition of “complaint” to address potential risks in onboarding and marketing

• Recommended clearer conduct reporting guidance on “serious misconduct” and selective inclusion of dealer-harming

behaviour that signals broader risks

• Endorsed the 90-day dispute resolution response and internal dispute resolution timeframes as appropriate, encouraging prompt resolution

• Supported a scalable dealer capital reporting model, and supported look through for diversified funds while noting

risks in niche or illiquid strategies

• Affirmed its view that the Dealer and Consolidated Rules (DC Rules) reflect the project’s objectives without introducing undue burden, and praised CIRO’s engagement with stakeholders through the process

Other letters filed:

• CFA Institute – GIPS Standards for Verifiers When Verifying Asset Owners Exposure Draft

Who is CFA Societies Canada?

CFA Societies Canada represents the twelve Canadian CFA Institute Member Societies and, ultimately, Canadian CFA charterholders. CFA Societies Canada’s Canadian Advocacy Council includes investment professionals from across the country who review regulatory, legislative, and standard-setting developments affecting investors, investment professionals, and Canadian capital markets. CFA Societies Canada through its advocacy efforts 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.

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, please contact

info@cfacanada.org.

Follow CFA Societies Canada on LinkedIn.

CFA Societies Canada Quarterly Update

June 29, 2026