As we discussed earlier this month, the CSA recently proposed amendments to National Instrument 31-103 Registration Requirements and Exemptions (31-103) relating to the registration of international investment fund managers and registration of domestic investment fund managers in additional provinces and territories.

Under the proposals, specific thresholds would preclude an international investment fund manager from relying on the exemption from registration. Similar thresholds, however, were not included for non-resident investment fund managers. As such, the Ontario Securities Commission and the Autorité des marchés financiers have issued an additional request for comments on whether threshold limitations proposed for international investment fund managers should also be applied to non-resident investment fund managers.

Comments on the issue are being accepted until January 13, 2011. For more information, see CSA Notice 31-320.