Yesterday, the CSA released its latest installment in a series of publications proposing enhancements to the registrant-client relationship. In addition to targeted reforms to National Instrument 31-103, this latest consultation paper proposes an over-arching best interest standard against which all other client obligations would be measured. While Ontario and New Brunswick’s regulators appear fully on board, the British Columbia Securities Commission has come out in strong opposition to the best interest standard. Comments on the consultation paper will be accepted until late August.
As we discussed in our February bulletin, issuers will be subject to new exempt market filing requirements beginning May 24, 2016, meant to streamline the filing process in provinces and territories that do not currently utilize electronic filing portals (all except Ontario and BC). Certain regulatory filings relating to exempt market activities will now need to be filed through SEDAR, including, among others, Form 45-106F1 Report of Exempt Distribution, and an offering memorandum under the offering memorandum exemption.