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 Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure June 29, 2020
CIRI submitted comments to the CSA on Proposed National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure. We agree with and strongly endorse the concept of improved non-GAAP financial disclosure and are therefore generally supportive of this initiative. That said, we are mindful of the regulatory burden on issuers. To this end, we made a recommendation for non-GAAP financial measures used in news releases.
CIRI Comments on the Ontario Securities Act May 20, 2020
CIRI submitted comments to the Taskforce to Review Capital Markets on the Ontario Securities Act. We strongly support this initiative and congratulate the Government of Ontario for reviewing the Act in an effort to not only modernize and streamline it, but to improve it. CIRI believes that transparency and market efficiency can be best enhanced through regulatory simplification. To this end, we made a number of recommendations.
CIRI Comments on Proposed Changes to CSA Consultation Paper 51-405 - Consideration of an Access Equals Delivery Model March 9, 2020
CIRI made a submission to the CSA supporting the proposed amendments to move to an access equals delivery model in an effort to further reduce the regulatory burden on issuers. This proposal relates to enhancing electronic delivery of disclosure documents by issuers to stakeholders through an access equals delivery model, which may replace Notice and Access.
CIRI Comments on Proposed Amendments to National Instrument 51-102 & Changes to the BAR December 4, 2019
CIRI made a submission to the CSA supporting proposed changes to the Business Acquisition Reports (BAR). These changes included incorporating a two-trigger test regime and increasing the significance test threshold from 20% to 30%. While these are positive steps to reducing the regulatory burden on issuers, CIRI believes more could be done.
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.

Archived Submissions

CIRI Comments on Proposed National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure June 29, 2020
CIRI submitted comments to the CSA on Proposed National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure. We agree with and strongly endorse the concept of improved non-GAAP financial disclosure and are therefore generally supportive of this initiative. That said, we are mindful of the regulatory burden on issuers. To this end, we made a recommendation for non-GAAP financial measures used in news releases.
CIRI Comments on the Ontario Securities Act May 20, 2020
CIRI submitted comments to the Taskforce to Review Capital Markets on the Ontario Securities Act. We strongly support this initiative and congratulate the Government of Ontario for reviewing the Act in an effort to not only modernize and streamline it, but to improve it. CIRI believes that transparency and market efficiency can be best enhanced through regulatory simplification. To this end, we made a number of recommendations.
CIRI Comments on Proposed Changes to CSA Consultation Paper 51-405 - Consideration of an Access Equals Delivery Model March 9, 2020
CIRI made a submission to the CSA supporting the proposed amendments to move to an access equals delivery model in an effort to further reduce the regulatory burden on issuers. This proposal relates to enhancing electronic delivery of disclosure documents by issuers to stakeholders through an access equals delivery model, which may replace Notice and Access.

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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