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 on Proposed National Systems Renewal Program Rule and Related Amendments July 30, 2019
CIRI made a submission to the CSA supporting the proposed replacement of SEDAR with a Renewed System and the simplified fee structure. We also raised the issue of subscribers potentially receiving access to regulatory filings before the general public. We encouraged the CSA to review this when implementing the Renewed System so that all individuals have simultaneous access to filings, allowing for fair and efficient capital markets.
CIRI Comments on CSA Consultation Paper 51-404 Considerations for Reducing Regulatory Burden for Non-Investment Fund Reporting Issuers July 31, 2017
CIRI made a submission to the Canadian Securities Administrators (CSA) on Consultation Paper 51-404: Considerations for Reducing Regulatory Burden for Non-Investment Fund Reporting Issuers.
CIRI's Comments Regarding OSC Statement of Priorities for Financial Year to End March 31, 2018 May 23, 2017

CIRI made a submission to the OSC on their Statement of Priorities for 2017-2018.

CIRI Comments on Proposed Amendments to the TSX Company Manual Part IV, and Part VI May 8, 2017
CIRI made a submission to the TSX on proposed changes to website disclosures in Parts IV and VI of the TSX Company Manual.
CIRI Comments on Bill C-25, An Act to amend the Canadian Business Corporations Act (CBCA) February 21, 2017
CIRI made a submission to the House of Commons Standing Committee on Industry, Science and Technology regarding Bill C-25, an act to amend the Canadian Business Corporations Act (CBCA). This is CIRI’s second submission. The initial submission was done on May 15, 2014.

Archived Submissions

CIRI Comments on Proposed National Systems Renewal Program Rule and Related Amendments July 30, 2019
CIRI made a submission to the CSA supporting the proposed replacement of SEDAR with a Renewed System and the simplified fee structure. We also raised the issue of subscribers potentially receiving access to regulatory filings before the general public. We encouraged the CSA to review this when implementing the Renewed System so that all individuals have simultaneous access to filings, allowing for fair and efficient capital markets.

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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