Submissions

The Committee issues Submissions to the regulatory authorities to effect change.  A Submission may be published as a response to a request for comment, or on a proactive basis, when CIRI believes an issue has high importance to the IR profession.

Latest Submissions

CIRI Comments to OSC on Proposed Amendments to National Instrument 51-102 Continuous Disclosure Obligations and Feedback on a Proposed Framework for Semi-Annual Reporting – Venture Issuers on a Voluntary Basis September 17, 2021
CIRI has provided (a) comments on the Proposed Amendments to National Instrument 51-102 (Proposed Amendments) and (b) feedback on the Proposed Framework for Semi-Annual Reporting (Proposed Framework). CIRI membership represents approximately 200 non-investment fund reporting issuers with a combined market capitalization of $3.1 trillion.  
CIRI Comments to the BCSC on Proposed National Instrument 51-519: Promotional Activity Disclosure Requirements August 3, 2021
CIRI submitted comments to the BCSC on Proposed National Instrument 51-519: Promotional Activity Disclosure Requirements, which would apply to issuers across Canada. In our recommendations, we strongly urge the BCSC not include ‘investor relations activity’ in the definition of ‘promotional activity’ among other things.
CIRI Comments on Innovation, Science, and Economic Development Canada's Consultation Paper March 31, 2021
CIRI submitted comments to Innovation, Science, and Economic Development Canada on their Consultation Paper regarding upcoming changes to the CBCA. Our comments focused on how and when the results of the soon to be mandated non-binding say-on-pay vote should be disclosed.

CIRI Comments on CSA Consultation Paper 25-403 - Activist Short Selling February 25, 2021
CIRI submitted comments to the CSA on their Consultation Paper on activist short selling. Given the devastating impact activist short selling can have on an issuer, we recommended that a regulatory regime be introduced to provide oversight, enhance disclosure and demand accountability.
CIRI Comments on the Consultation Paper on the Ontario Securities Act September 8, 2020
CIRI submitted comments to the Capital Markets Modernization Taskforce on their Consultation Paper on the Ontario Securities Act. This Consultation Paper aims to modernize the Act to foster vibrant capital markets that are driven by innovation, competition and diversity. CIRI was supportive of many of the proposals, as outlined in our submission.

Archived Submissions

CIRI Comments to OSC on Proposed Amendments to National Instrument 51-102 Continuous Disclosure Obligations and Feedback on a Proposed Framework for Semi-Annual Reporting – Venture Issuers on a Voluntary Basis September 17, 2021
CIRI has provided (a) comments on the Proposed Amendments to National Instrument 51-102 (Proposed Amendments) and (b) feedback on the Proposed Framework for Semi-Annual Reporting (Proposed Framework). CIRI membership represents approximately 200 non-investment fund reporting issuers with a combined market capitalization of $3.1 trillion.  
CIRI Comments to the BCSC on Proposed National Instrument 51-519: Promotional Activity Disclosure Requirements August 3, 2021
CIRI submitted comments to the BCSC on Proposed National Instrument 51-519: Promotional Activity Disclosure Requirements, which would apply to issuers across Canada. In our recommendations, we strongly urge the BCSC not include ‘investor relations activity’ in the definition of ‘promotional activity’ among other things.
CIRI Comments on Innovation, Science, and Economic Development Canada's Consultation Paper March 31, 2021
CIRI submitted comments to Innovation, Science, and Economic Development Canada on their Consultation Paper regarding upcoming changes to the CBCA. Our comments focused on how and when the results of the soon to be mandated non-binding say-on-pay vote should be disclosed.

CIRI Comments on CSA Consultation Paper 25-403 - Activist Short Selling February 25, 2021
CIRI submitted comments to the CSA on their Consultation Paper on activist short selling. Given the devastating impact activist short selling can have on an issuer, we recommended that a regulatory regime be introduced to provide oversight, enhance disclosure and demand accountability.

Recent Submission

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CIRI Comments on CSA Proposed Amendments to the Early Warning System

CIRI has submitted comments to the CSA on proposed amendments NI 62-103 Early Warning Systems and Related Take-Over Bid and Insider Reporting Issues published in March.

CIRI's submission illustrates that Canada's early warning threshold are too high and includes multiple recommendations to the CSA including a reduction in the beneficial ownership threshold.

Click here to learn more.

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