The IIAC provided comments to the Canadian Investment Regulatory Organization (CIRO) on its proposed enhanced cost reporting amendments to the Investment Dealer and Partially Consolidated Rules and the Mutual Fund Dealer Rules.

We generally agree with CIRO’s conclusion that the impact of the Proposed Amendments is derivative of the Canadian Securities Administrators’ enhanced cost reporting amendments to National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations.

There are areas of the Proposed Amendments that would benefit from revision. These relate to:

(a) the impact on the Proposed Amendments on existing reporting exemptions for outside holdings.

(b) reporting obligations for total fund expenses and fund expense ratios.

(c) notifications related to funds with managers in foreign jurisdictions; and

(d) the inclusion of precious metal bullion in the Proposed Amendments.

Our position on each of these discrete issues is detailed in our comment letter.