Re: OSC Notice 11-780 Statement of Priorities – Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2019
The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding OSC Notice 11-780 Statement of Priorities – Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2019 (the Statement of Priorities).
As background, PMAC represents over 250 investment management firms registered to do business in Canada as portfolio managers. In addition to this primary registration, many members are dually registered as investment fund mangers and/or exempt market dealers. PMAC members encompass both large and small firms managing total assets in excess of $1.8 trillion for institutional and private client portfolios.
PMAC is consistently supportive of measures that elevate standards in the industry and improve investor protection. We applaud the efforts made by the Ontario Securities Commission (OSC) to date in this respect, as well as the principles set out in the Statement of Priorities for 2019.
As with past years, PMAC’s goals as an association continue to be very closely aligned with the goals set out in the Statement of Priorities and we would like to take this opportunity to thank the OSC and its colleagues that form the Canadian Securities Administrators (CSA) for the opportunity to participate in various formal and informal consultations around issues of importance to our members and, ultimately, to Canadian investors. Similarly, we commend the OSC for its outreach to registrants and market participants to promote compliance, improve enforcement, and to discuss and seek feedback on new and ongoing initiatives.
PMAC continues to support and champion the efforts of the CSA to identify opportunities to promote investor protection and to improve the registrant regulatory framework. Our mission statement is “advancing standards” and we believe that the opportunity to provide feedback on regulatory priorities is an important way to lend support for the OSC’s work, as well as to highlight salient aspects of recent relevant PMAC submissions that can support these goals. Due to the long-term nature of many of the important projects being undertaken by the OSC and its CSA colleagues, some of our recommendations echo those made in previous submissions on past years’ Statements of Priorities.