AIMA Canada Regulatory Comment Letters
The AIMA Canada Regulatory Comment Letters are listed below:
1. This letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and Alternative Credit Councl ("ACC") to provide comments on OSC Consultation 81-737 (Feb 7, 2025)

2. This letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) to provide comments on Canada Financial Institutions Statutes Review. (Sep 13, 2024)

3. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide provide our comments on Qualified Investments for Tax-Advantaged Savings Plans. (Jul 15, 2024)

4. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide a letter to the Canadian Securities Administrators (CSA) for open feedback and industry comments. (Jul 8, 2024)

5. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide a response to to the Canadian Securities Administrators (“CSA”) proposals for investment funds seeking to invest in crypto assets. (Apr 17, 2024)

6. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the CIRO Proposed Amendments Respecting the Reasonable Expectation to Settle a Short Sale (Apr 12, 2024)

7. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the Staff Notice 23-329 - Short Selling in Canada published jointly by the Canadian Securities Administrators (CSA) and Investment Industry Regulatory Organization of Canada (IIROC). (Mar 8, 2023)

8. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments to you on the CSA and CCIR Joint Notice and Request for Comment – Proposed Amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and to Companion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations and Proposed CCIR Individual Variable Insurance Contract Ongoing Disclosure Guidance – Total Cost Reporting for Investment Funds and Segregated Funds (collectively the “Notice”) (Aug 4, 2022)

9. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the NI 81-102 PER OSC INVESTMENT FUND & STRUCTURED PRODUCT BRANCH REQUEST

10. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the Department of Finance Canada of Finance (Canada) consultations on the excessive interest and financing expenses limitation (“EIFEL”) tax amendments (May 4, 2022)

11. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the CSA Notice and Third Request for Comment – Proposed National Instrument 93-101 Derivatives: Business Conduct, Proposed Companion Policy 93-101CP Derivatives: Business Conduct (collectively the “Notice”) (March 21, 2022)

12. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the Mutual Fund Dealers Association of Canada Proposed New Policy No.11 - Proficiency Standards for the Sale of Alternative Mutual Funds (January 24, 2022)

13. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the OSC Staff Notice 33-753 - OSC Consultation on Tied Selling and other Anti-Competitive Practices in the Capital Markets (January 10, 2022)

14. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the Proposed Amendments to National Instrument 33-109 and related instruments; Proposed Amendments to National Instrument 33-109 Registration Information and Changes to Companion Policy 33-109CP Registration Information and Related Amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and Changes to Companion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations (the “Proposals”) (May 5, 2021)

15. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the CSA Consultation Paper 25-403 – Activist Short Selling (March 3, 2021)

16. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the CSA Consultation Paper 25-402 – Consultation on the Self-Regulatory Organization Framework (October 23, 2020)

17. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on Consultation — Modernizing Ontario’s Capital Markets (September 7, 2020)

18. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on CSA Notice and Request for Comment Reducing Regulatory Burden for Investment Fund Issuers – Phase 2, Stage 1 (December 11, 2019)

19. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on Consultation on transfers for processing – a Reframed discussion document (August 6, 2019)

20. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the OSC Staff Notice 11-784 Burden Reduction (March 1, 2019)

21. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on Client Focused Reforms—Proposed Amendments to National Instrument 31-103 and Companion Policy 31-103 (October 19, 2018)

22. This comment letter is submitted on behalf of the Canadian division (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on the Canadian Securities Administrators (“CSA”) Notices and Request for Comment – Proposed National Instrument 93-101 Derivatives: Business Conduct and Proposed Companion Policy 93-101 Derivatives: Business Conduct (the “Business Conduct Proposal”) and National Instrument 93-102 Derivatives: Registration and Proposed Companion Policy 93-102 Derivatives: Registration (the “Registration Proposal”) (collectively the “Proposals”) (September 16, 2018)

23. This comment letter was submitted on behalf of the Canadian section (“AIMA Canada”) of the Alternative Investment Management Association (“AIMA”) and its members to provide our comments on Canadian Securities Administrators (“CSA”) Consultation Paper 81-408 – Consultation on the option of discontinuing embedded commissions (“the Consultation Paper”) (June 9, 2017)
