On January 31, 2025, the IIAC responded to the CSA’s request for comments on its proposed amendments to modernize the continuous disclosure regime for investment funds. According to the request for comments, the CSA’s proposal is intended to improve the quality of disclosure provided to investors while reducing the regulatory burdens associated with the continuous disclosure obligations of investment funds. The proposed amendments implicate several instruments and companion policies including National Instrument 81-101, Mutual Fund Prospectus Disclosure.
In substance, the CSA’s proposed amendments are designed to: (a) replace the annual Management Report of Fund Performance (MRFP) and the interim MRFP with a new annual and interim report to streamline reporting requirements and respond to the needs and preferences of investors; (b) provide an exemption from provincial statutory requirements to report conflicts of interest and related party transactions where a fund is already subject to separate but similar reporting obligations; and (c) eliminate certain class or series-level disclosure requirements for investment fund financial statements that are not required by international financial reporting standards.
The IIAC supports the CSA’s efforts to improve the continuous disclosure regime for investment funds. The IIAC has made a series of recommendations to improve the CSA’s proposal, which include, among other things:
- Eliminating the MRFP in favour of disclosure through enhanced financial statement,
- Reassessing class/series-based disclosure requirements, and
- Removing the proposed requirement to disclose fund “success” in achieving investment objectives.
Read the full submission here.
