The PCMA monitors key issues affecting the private capital markets, in particular securities regulations that impact two key areas: 

1. Registration and compliance issues for exempt market dealers including National Instrument NI 31-103 and related regulations; and 
2. Prospectus and exempt product/trade rules for issuers, dealers and investors including National Instrument 45-106 and related regulations.  

The PCMA regularly provides detailed written submissions to securities regulators, we meet regularly with senior staff from provincial securities commissions and several members of the Executive and Board have been appointed to advisory roles with securities commissions.  

Recent PCMA comment letters and formal regulatory submissions

• January 31, 2022: PCMA Response to Independent Evaluation of the Ombudsman for Banking Services and Investments with Respect to Investment Related Companies

• January 10th, 2022: PCMA Response to OSC Staff Notice 33-753        

• May 13th, 2021: PCMA Response To CSA Multilateral Notice and Request for Comment Proposed Order 45-539 Small Business Financing

• May 7, 2021: PCMA Response To Proposed Revocation of ASC Blanket Order 31-505 Registration Exemption for Trades in Connection with Certain Prospectus Exempt Distributions and Replacement with Proposed ASC Blanket Order 31-536 Alberta Small Business Finder’s Exemption

•  May 5, 2021 PCMA Response To Modernizing Registration Information Requirements, Clarifying Outside Activity Reporting And Updating Filing Deadlines in Connection with the Proposed Changes

• December 23, 2020: PCMA Comment Letter Re: 45-327 Proposed Prospectus Exemption for Self Certified Investors

• December 16, 2020: PCMA Comment Letter Re: Statement of Priorities for Financial Year to End March 31, 2022 

• October 23, 2020: PCMA Comment Letter Re: CSA Consultation Paper 25-402 Consultation on the Self-Regulatory Organization Framework

• September 30, 2020:  PCMA Comment Letter Re: CSA Staff Notice 31-358 Guidance on Registration Requirements for Chief Compliance Officers

• September 11, 2020:  PCMA Comment Letter for Ontario's Capital Markets Modernization Taskforce 

• July 13, 2020:  PCMA Comment Letter on Proposed National Institute 45-110 Startup Crowdfunding Registration and Prospectus Exemptions

• November 20, 2019:   PCMA Comment Letter on the legislative review of Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA)

• September 20, 2019:  PCMA Comment Letter regarding ASC 11-701, Energizing Alberta's Capital Markets

• May 14, 2019:  Comment Letter on Proposed Amendments Relating to Syndicated Mortgages

• March 1, 2019 - PCMA Comment Letter: OSC Staff Notice 11-784 Burden Reduction and PCMA Suggestions to Reduce Regulatory Burden 

• Please review our SPECIAL FEATURE illustrating our efforts to bring the OM exemption to Ontario issuers and investors.