Part of PMAC’s primary mandate is to advocate members’ views to security regulators and other levels of government. Given our members’ manage a significant portion of Canada’s personal retirement savings and pension portfolios, many of our advocacy efforts are focused on promoting fair and effective regulation and tax policy that protects Canadian’s savings.
PMAC’s advocacy efforts
April 10, 2012
Submission on Proposed Multilateral Instrument 32-102 Registration Exemptions for Non-Resident Investment Fund Managers and Companion Policy 32-102CP
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April 10, 2012
Submission on Notice of and Request for Comment on Proposed Multilateral Policy 31-202 Registration Requirement for Investment Fund Managers
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April 5, 2012
Submission to Department of Finance on Designated Stock Exchange Expansion
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March 14, 2012
PMAC Submits Request for Interpretation to CRA on Prohibited Investment Rules (RRSPs and RRIFs)
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We are writing to seek a written interpretation on the application of the
”Prohibited Investment” Rules under section 207.01, Part X1.01 of the Income Tax Act (the “Act”) and specifically, the arm’s length test as it applies to certain of our members.
March 9, 2012
AMF’s Notice and Request for Comment regarding compensation of consumers of financial products and services
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The Portfolio Management Association of Canada (“PMAC”, formerly the Investment Counsel Association of Canada (ICAC)), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding the Autorité des marchés financiers (“AMF”) Notice and Request for Comment regarding compensation of consumers of financial products and services (the “Notice”) published on December 9, 2011.
March 8, 2012
Second Submission to Department of Finance on Prohibited Investment Rules under Part XI.01 of the Income Tax Act – RRSPs and RRIFs
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Further to our discussion on February 9, 2012 and our letter of December 13, 2011 where we discussed the ”prohibited investment” Rules under Part X1.01 of the Income Tax Act (the “Act”) (the “Rules”), please find enclosed additional submissions regarding the specific concerns of our members and the impact of the Rules on our membership.
February 29, 2012
CSA Staff Consultation Note 45-401 Review of Minimum Amount and Accredited Investor Exemptions – Public Consultation
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The Portfolio Management Association of Canada (“PMAC”, formerly the Investment Counsel Association of Canada (“ICAC”)), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding CSA Staff Consultation Note 45-401 Review of Minimum Amount and Accredited Investor Exemptions – Public Consultation (the “Consultation Note”). We also appreciate the opportunity that we had to meet directly with staff of the Ontario Securities Commission (OSC) on February 21st, 2012 to share our views.
February 15, 2012
NI 31-103 Dispute Resolution Service (section 13.16)
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Further to our letter of May 18, 2011, this letter is to inform you that the Portfolio Management Association of Canada (“PMAC”) has launched the dispute resolution program in which we have partnered with the ADR Institute of Canada (ADRIC). The purpose of this program is to facilitate dispute resolution services for PMAC member companies (PMAC Members) and their clients. This service is designed to comply with the requirement in NI 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) (s.13.16). PMAC Members may choose to participate in the ADRIC – PMAC Dispute Resolution Program in order to meet this requirement. We have attached for your reference a number of documents explaining the details of the program in addition to our letter of May 18, 2011.
February 14, 2012
Response to Department of Finance Canada – Proposed Tax Legislative Proposals for Pooled Registered Pension Plans (PRPPs)
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The Portfolio Management Association of Canada (“PMAC”, formerly the Investment Counsel Association of Canada (“ICAC”)), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to submit the following comments regarding consultation package of draft legislative proposals for changes to the Income Tax Act and the Income Tax Regulations to accommodate PRPPs (the “Proposed Rules”). We note that some of our comments below will reiterate key points communicated at previous round table discussions that PMAC attended (February 22, 2011 and July 4, 2011) and some comments pertain generally to the draft Pooled Registered Pension Plans Act (the “draft PRPP Act”).
February 9, 2012
PMAC Regulatory Alert – Prohibited Investment Rules – RRSPs and RRIFs
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