On February 4, the Canadian Securities Administrators (CSA) released a number of proposed changes to certain initial and ongoing regulatory reporting requirements for registrants. The CSA is inviting comments on these proposals by May 5. Some of the highlights of these proposed changes are:
- Outside Business Activities
As you know, registrants are currently required to report and update (within 10 days) all Outside Business Activities on their personal disclosure form (Form 33-109F4). The proposed changes seek to:
- Provide much clearer definition of what an “Outside Business Activity” is. This includes dropping the term “Business” from “Outside Business Activity” to further make clear that a reportable activity includes more than just a compensated position.
- Provide a fairly comprehensive set of evaluation criteria to assist a registrant in determining what is reportable to regulators and what is not. Some examples discussed include clarifications that activities like being a community hockey coach or being a director in a non-active holding company is typically not reportable.
- Extend the reporting deadlines.
- General Deadline Extensions
In addition to extending the reporting deadline for “Outside Activities” from 10 to 30 days, other areas of disclosure have also received extended reporting deadlines. The proposed new deadlines are generally listed as follows:
|Relevant Sections of Your Firm Registration Form (Form 33-109F6)||Deadline||Relevant Sections of Your Personal Registration Form (Form 33-109F4)||Deadline|
||15 Days (previously 10 days)||
||15 Days (previously 10 days)|
||30 Days (previously 10 days)||
||30 Days (previously 10 days)|
The above is just a high-level summary of the proposed changes. If you have additional questions about the above, please contact your usual lawyer at AUM Law to discuss.
February 26, 2021