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 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.
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.

Archived Submissions

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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