Our readers will recall that the Canadian Securities Administrators (CSA) have proposed to significantly expand the type of information required to be provided in private placement reports of trade.
As we discussed when this proposal was first published in August 2015, new or amended disclosure requirements would include detailed information on directors, executive officers, control persons and promoters (for certain types of issuers) as well as the identities of persons being compensated as a result of the distribution, and other significant changes for investment funds.
For certain non-public issuers other than investment funds, disclosure will be required of the identities of all directors, officers, control persons and promoters of the issuer and all directors and officers of non-individual control persons and promoters, along with the number of and total amount paid for any voting securities of the issuer held by such persons.
For investment funds, new disclosure items include net proceeds from the distribution by jurisdiction (which indirectly discloses redemptions), net asset value range, date of formation, jurisdictions where reporting, financial year end, stock exchange listings, and type of investment fund. In addition, if the investment fund manager does not have a National Registration Database number, the investment fund manager’s address, telephone number and website would have to be disclosed.