CSA Notice and Request for Comment - Testing Letter 1 - Canadian Securities Administrators

The Canadian Securities Administrators (the “CSA”) is seeking comments in all aspects of the Testing Letter 1. Please submit your comments through the form below by December 30, 2024

If you face technical issues, please contact csa-acvm-secretariat@acvm-csa.ca.

If you have questions regarding the consultation, please refer your questions to any of the following:

British Columbia Securities Commission Name Title email	Alberta Securities Commission Name Title email
Financial and Consumer Services Commission Authority of Saskatchewan Name Title email	Manitoba Securities Commission Name Title email
Ontario Securities Commission Name Title email	Autorité des marchés financiers Name Title email
Financial and Consumer Services Commission (New Brunswick) Name Title email	Nova Scotia Securities Commission Name Title email

The CSA is requesting comments on its proposals generally and is also seeking comments on the following specific questions. We provide space for you to provide general comments after our specific questions. We encourage you to provide your responses in the boxes provided as it will help us analyze your comments more efficiently, however if you wish you provide your comments in document, you can upload that document at the end of this form.

CSA Notice and Request for Comment - Testing Letter 1

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General

General Comments

1. Other Areas for Modernization

Are there any other areas of the continuous disclosure regime for investment funds that should be modernized, and which have not been addressed as part of this project? Please provide detailed rationale for each suggestion.

2. Effective Dates and Exemptions

As described in the Notice, the CSA is proposing that the final amendments and final changes have an effective date of three months following final publication. However, the CSA is also proposing time-limited exemptions from compliance with the final amendments and final changes. In particular, we are proposing to provide an exemption from compliance in respect of each Workstream and the FER Revisions, for approximately a 9-month period following the effective date. (See also the transition provisions at the end of each amending regulation, which have been drafted with the intention to give effect to these arrangements.)

a. In respect of each Workstream and the FER Revisions, please comment on whether the proposed effective date is appropriate and whether the proposed length of the exemption from compliance is sufficient to enable investment funds to prepare for the new requirements. If not, provide alternative timelines and an explanation of how any additional time would be used.

b. In respect of Workstream One – Fund Report, please comment on whether an investment fund that prepared an interim MRFP using the requirements set out in the Current Form 81-106F1 should be able to file its subsequent annual MRFP also using the requirements set out in the Current Form 81-106F1, even where the currently envisioned exemption period has ended. If yes, please explain why.

Workstream One – Fund Report

3. Frequency of Preparation

Currently, an investment fund that is a reporting issuer must file an annual MRFP and an interim MRFP (see section 4.2 of Regulation 81-106) and an investment fund that is a reporting issuer and a scholarship plan must file an annual MRFP but is not required to file an interim MRFP (see section 4.3 of Regulation 81-106). We are proposing that these filing requirements would remain unchanged for the Fund Report. Please comment on whether this proposed approach meets investor needs for remaining current as to the status of their reporting issuer investment fund holdings.

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CSA Notice and Request for Comment - Testing Letter 1

General

Workstream One – Fund Report

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