AIMA Canada Regulatory Comment Letters
The AIMA Canada Regulatory Comment Letters are listed below:
1. 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.
AIMA response to the Canadian Securities Administrators (“CSA”) proposals for investment funds seek.pdf
2. 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 Amendments re Reasonable Expections (Apr 12, 2024)
AIMA Canada Comments CIRO Amendments re Reasonable Expectations .pdf
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 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)
AIMA Canada Comments CSA and IIROC Short Selling in Canada
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 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)
AIMA Canada - Ltr Fund Total Cost Rptg
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 our comments on the NI 81-102 PER OSC INVESTMENT FUND & STRUCTURED PRODUCT BRANCH REQUEST
AIMA Canada - OSC NI 81 102 Request
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 Department of Finance Canada of Finance (Canada) consultations on the excessive interest and financing expenses limitation (“EIFEL”) tax amendments (May 4, 2022)
AIMA Canada - Tax Proposals Comment Letter May 4
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 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)
AIMA Canada - CSA Derivatives Mar 21.pdf
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 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)
AIMA Canada - MFDA Policy Comment Letter Jan 24.pdf
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 OSC Staff Notice 33-753 - OSC Consultation on Tied Selling and other Anti-Competitive Practices in the Capital Markets (January 10, 2022)
AIMA Canada - OSC Tied Selling Comment Letter January 10, 2021 Final.pdf
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 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)
AIMA Canada - 33-109 Comment Letter May 5.pdf
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 Consultation Paper 25-403 – Activist Short Selling (March 3, 2021)
AIMA Canada - CSA Activist Short Selling March 3, 2021.pdf
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 CSA Consultation Paper 25-402 – Consultation on the Self-Regulatory Organization Framework (October 23, 2020)
AIMA Canada - CSA SRO Consultation Final Oct 23, 2020.pdf
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 Consultation — Modernizing Ontario’s Capital Markets (September 7, 2020)
AIMA Canada - Ontario Capital Markets Modernization Consultation - Comments Sep 7, 2020.pdf
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 CSA Notice and Request for Comment Reducing Regulatory Burden for Investment Fund Issuers – Phase 2, Stage 1 (December 11, 2019)
AIMA_Canada_-_CSA_Regulatory Burden_Reduction_Comment_Letter Final December 11, 2019.pdf
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 Consultation on transfers for processing – a Reframed discussion document (August 6, 2019)
AIMA Canada - OPC Comment Letter Aug 6, 2019.pdf
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 OSC Staff Notice 11-784 Burden Reduction (March 1, 2019)
AIMA_Canada_-_OSC_Burden_Reduction_Comment_Letter Final March 1 2019.pdf 1
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 Client Focused Reforms—Proposed Amendments to National Instrument 31-103 and Companion Policy 31-103 (October 19, 2018)
AIMA Canada CSA Client Focused Reforms Final Letter October 19, 2018.pdf 1
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 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)
AIMA Canada CSA Derivatives Letter September 16, 2018.pdf 1
19. 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)
AIMA Canada Comment Letter - Embedded Commissions June 9, 2017.pdf