The Canadian Securities Administrators (“CSA”) and the Ontario Securities Commission have announced proposed changes to the exempt market dealer (“EMD”) registration requirements that are expected to make it tougher to register as an EMD.

The CSA has recently announced that, effective January 11, 2015, chief compliance officers for EMDs will now have to satisfy certain experience requirements before registration will be granted. In addition, Ontario is seeking to require that EMD applicants answer questions regarding their business models and policies and procedures manual, and provide their answers either in written form or by way of an in-person interview.

Prospective chief compliance officers and EMDs should carefully assess the effect of these proposed changes on their registration process.