News and Publications

PCMA Advocacy: Comment Letter on the Proposed OSC Rule 72-503.

Tue, 11 Oct 2016 15:09:09 GMT

On October 7, 2016 the PCMA submitted a comment letter regarding proposed OSC Rule 72-503 Distributions Outside of Canada and Companion Policy 72-503 to OSC Rule 72-503 Distributions Outside of Canada. Please review the comment letter HERE.

As the strong national voice for the private capital markets/exempt market, the PCMA constantly monitors key issues affecting the private capital markets/exempt market. The PCMA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

We value your opinion! Please send us your questions, comments and views to info@pcmacanada.com and help shape the PCMA response to the future proposals.

Your consideration is greatly appreciated!

PCMA Advocacy: Comment Letter on the CSA Consultation Paper 33-404.

Fri, 30 Sep 2016 15:46:41 GMT

On September 29, 2016 the PCMA submitted a comment letter regarding the CSA Consultation Paper 33-404 – Proposals to Enhance the Obligations of Advisors, Dealers, and Representatives towards their Clients. Please review the comment letter HERE.

As the strong national voice for the private capital markets/exempt market, the PCMA constantly monitors key issues affecting the private capital markets/exempt market. The PCMA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

We value your opinion! Please send us your questions, comments and views to info@pcmacanada.com and help shape the PCMA response to the future proposals.

Your consideration is greatly appreciated!

PCMA Advocacy: Comments on the Revised Consultation Draft of the Capital Markets Stability Act.

Thu, 4 Aug 2016 22:45:04 GMT

On July 6, 2016 the PCMA submitted a comment letter to the Co-operative Capital Markets Regulatory System Participating Jurisdictions in connection with the revised draft Capital Markets Stability Act (the “CMSA”). Please review the comment letter HERE.

As the strong national voice for the private capital markets/exempt market, the PCMA constantly monitors key issues affecting the private capital markets/exempt market. The PCMA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

We value your opinion! Please send us your questions, comments and views to info@pcmacanada.com and help shape the PCMA response to the future proposals.

Your consideration is greatly appreciated!

PCMA Advocacy: Comments to proposed Amendments to National Instrument 13-101 SEDAR

Tue, 1 Sep 2015 20:58:04 GMT

On August 31, 2015, PCMA published “Comments and Analysis of the Proposed Amendments” in response to proposed amendments to National Instrument 13-101 System for Electronic Document Analysis and Retrieval (SEDAR) (N-13-101) and Multilateral Instrument 13-102 System Fees for SEDAR and NRD. Please review the comment letter HERE.

As the strong national voice for the private capital markets/exempt market, the PCMA constantly monitors key issues affecting the private capital markets/exempt market. The PCMA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

We value your opinion! Please send us your questions, comments and views to info@pcmacanada.com and help shape the PCMA response to the future proposals.

PCMA comments on proposed amendments to NI 31-103 and related rules published by the CSA on December

Wed, 5 Mar 2014 20:27:22 GMT

The Private Capital Markets Association of Canada (PCMA) (formerly the Exempt Market Dealers Association of Canada) submitted a comment letter in connection with the proposed amendments to NI 31-103 and related rules published by the CSA on December 5, 2013.

The comment letter tackled some complicated issues critical to our members involving

EMDs and prospectus offerings
CCOs and the proposed experience requirement
Registration exemption for trades through a dealer

Please review the comment letter HERE.

As the strong national voice for the private capital markets/exempt market, the PCMA constantly monitors key issues affecting the private capital markets/exempt market. The PCMA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

EMDA comments on Multilateral CSA Notice 45-312 Proposed Prospectus Exemption

Tue, 21 Jan 2014 03:00:35 GMT

The Exempt Market Dealers Association of Canada (the EMDA) made a submission in response to the request for comments published by the Canadian Securities Administrators (the CSA) on November 21, 2013 in connection with the Proposed Exemption.

The EMDA is broadly supportive of the Proposed Exemption and applauds the introduction of appropriately designed prospectus exemptions designed to facilitate fair and efficient capital raising and investor protection in the Canadian marketplace. We are mindful, however, that not all CSA members have agreed to adopt the Proposed Exemption, but are optimistic that if implemented, the Proposed Exemption will be adopted in a uniform fashion across Canada. We encourage the CSA to continue to work with the securities regulators in Ontario and Newfoundland and Labrador to ensure a consistent adoption of this and other prospectus exemptions across Canada.

Please review the comment letter here.

As the strong national voice for the exempt market, the EMDA constantly monitors key issues affecting the exempt market. The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

EMDA comments on the OSC’s 2013-2014 Statement of Priorities

Tue, 4 Jun 2013 17:00:39 GMT

EMDA comments on the OSC’s 2013-2014 Statement of Priorities

This submission is made by the Exempt Market Dealers Association of Canada (EMDA) in response to the request for comments published by the Ontario Securities Commission (OSC) on April 4, 2012 in connection with the OSC’s 2013-2014 Statement of Priorities.

Please review the comment letter here.

As the strong national voice for the exempt market, the EMDA constantly monitors key issues affecting the exempt market. The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

EMDA comments on OSC Considerations for New Capital Raising Prospectus Exemptions

Tue, 12 Mar 2013 17:00:00 GMT

The Exempt Market Dealers Association of Canada (EMDA) has submitted its response to the request for comments published by the Ontario Securities Commission (OSC) on December 14, 2012 in connection with the OSC Staff Consultation Paper 45-710 Considerations for New Capital Raising Prospectus Exemptions.

The comment letter was submitted on March 8, 2013 and can be reviewed here.

As the strong national voice for the exempt market, the EMDA constantly monitors key issues affecting the exempt market. The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

EMDA Comments on the Revocation of the NW/MIE Exemptions

Wed, 27 Feb 2013 19:33:40 GMT

The Exempt Market Dealers Association of Canada (EMDA) has submitted its response to the request for comments published by the British Columbia Securities Commission (BCSC) on January 3, 2013 in connection with the Revocation of the NW/MIE Exemptions

The comment letter was submitted on February 27, 2013 and can be reviewed here.

As the strong national voice for the exempt market, the EMDA constantly monitors key issues affecting the exempt market. The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

EMDA comments on CSA proposal for a fiduciary duty standard

Fri, 22 Feb 2013 21:00:20 GMT

The EMDA provided comments to the CSA on their Consultation Paper 33-403: The Standard of Conduct for Advisers and Dealers: Exploring the Appropriateness of Introducing a Statutory Best Interest Duty When Advice is Provided to Retail Clients.

The comment letter was submitted on February 22, 2013 and can be reviewed here.

As the strong national voice for the exempt market, the EMDA constantly monitors key issues affecting the exempt market. The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

The EMDA responds to OBSI dispute resolution proposal from CSA

Tue, 19 Feb 2013 20:00:00 GMT

The EMDA has responded to the CSA's proposal to mandate OBSI as the dispute resolution provider for EMDs (and all registrants). The EMDA is concerned that the OBSI is ill-equipped to service the exempt market and the potential costs to EMDs are unclear and may be high causing unnecessary burden on EMDs.

The comment letter was submitted on February 15, 2013 and can be reviewed here.

As the strong national voice for the exempt market, the EMDA constantly monitors key issues affecting the exempt market. The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals.

All comment letters can be found on our website under Advocacy section.

EMDA comments on Accredited Investor and Minimum Amount review by CSA

Wed, 14 Mar 2012 21:40:49 GMT

In recent months, the EMDA has hosted member networking events, lead an extensive consultation on the Accredited Investor and Minimum Amount issue with Town Hall meetings in Halifax, Vancouver and Calgary, launched our first industry survey, and met with staff from the securities commissions in British Columbia, Alberta, Ontario, New Brunswick and Nova Scotia.

EMDA greatly appreciates everyone's feedback and comments that helped us respond to regulators on Accredited Investor and Minimum Amount review by CSA.

All comment letters can be found on our website under Advocacy section.

EMDA raises concerns about treatment of EMDs under new securitization rules

Tue, 6 Sep 2011 17:05:34 GMT

The EMDA has voiced concerns regarding the CSA's proposed restrictions on EMDs participating in the securitization markets across Canada. The EMDA's comments and analysis was delivered in a formal submission to the CSA on August 31, 2011.

To view the EMDA submission Click Here

The proposed rules establish a new regulatory framework for securitized products which the EMDA believes are not warranted. The proposals include significant changes to existing exempt market practices including: offering documents, continuous disclosure obligations and restrictions on EMDs participating on behalf of their exempt market clients.

All comment letters can be found on our website under Advocacy section.

EMDA proposes Provincial and Regional Advisory Councils

Tue, 23 Aug 2011 03:52:11 GMT

The EMDA wants your input on our proposed Regional and Provincial Advisory Councils!

EMDA members across Canada will soon have the opportunity to participate at a grassroots level in the development of the EMD industry in their home province. The EMDA has proposed the establishment of Provincial and Regional Advisory Councils to develop and support initiatives that respond to local needs in the exempt market industry.

"We are excited about the opportunity for continued growth of the EMDA and welcome your input and comments on our proposal before it is introduced across Canada" said EMDA President Brian Prill. "Our objective is to develop a national EMD association with active and vibrant provincial and regional representation across Canada."

The EMDA Provincial and Regional Advisory Councils will work closely with the national EMDA Board of Directors and Executive Committee in developing programs for EMDs and speaking up for the needs of the exempt market across Canada. The proposal will be finalised in September and officially launched in October 2012. A call for nominations to join the Provincial and Regional Councils will be circulated in September - stay tuned!

Our proposal can be accessed here: EMDA Provincial and Regional Advisory Councils - Concept Proposal

All comment letters can be found on our website under Advocacy section.

EMDA reacts to regulatory bias against EMDs in proposed direct market access rules from the CSA

Thu, 28 Jul 2011 17:38:11 GMT

The EMDA has expressed serious concerns about the proposed exclusion of EMDs under the new direct market access regime. The EMDA's comments and analysis was delivered in a formal submission to the CSA on July 8, 2011.

To view the EMDA submission Click Here

The proposed rules would exclude EMDs from eligibility as a direct market access clients and the EMDA believes the proposals reflect an unwarranted regulatory bias against EMDs. The EMDA has argued that EMDs should be eligible direct market access clients, rejects the unlevel playing field the proposed rules create, and the negative consequences for international dealers and EMDs who are also portfolio managers.

All comment letters can be found on our website under Advocacy section.