CSA Notice and Request for Comment - Liquidity Risk Management

The CSA has proposed amendments to National Instrument 81-102 Investment Funds and the companion policy relating to liquidity risk management (LRM) for all investment funds. These proposals focus on three key areas – a fund’s LRM framework, operational LRM matters, and oversight of the LRM framework. In addition, the CSA has published a consultation paper that seeks feedback on potential further changes to the regulatory framework for LRM. The paper explores LRM tools, liquidity classification of underlying portfolio assets, and regulatory disclosure and data relating to LRM.

Closing Consultation Date: March 27, 2026

submit your comment

Publication materials can be found on the website of the participating jurisdictions:
Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Northwest Territories, Nova Scotia, Nunavut, Ontario, Prince Edward Island, Québec, Saskatchewan, Yukon

Questions about this proposal? Please refer to any of the following:

BC Securities Commission James Leong Senior Legal Counsel Corporate Finance Phone: 604-899-6681 jleong@bcsc.bc.ca
Alberta Securities Commission Jan Bagh Senior Legal Counsel Corporate Finance Phone: 403-355-2804 jan.bagh@asc.ca	Melissa Yeh Legal Counsel Corporate Finance Phone: 403-355-4181 melissa.yeh@asc.ca
Financial and Consumer Affairs Authority of Saskatchewan Heather Kuchuran Director Corporate Finance Phone: 306-787-1009 heather.kuchuran@gov.sk.ca
Manitoba Securities Commission Patrick Weeks Deputy Director Corporate Finance Phone: 204-945-3326 patrick.weeks@gov.mb.ca
Ontario Securities Commission Ritu Kalra Senior Accountant Investment Management Phone: 416-721-3847 rkalra@osc.gov.on.ca Stephen Paglia Vice President Investment Management Phone: 416-593-2393 spaglia@osc.gov.on.ca	Bryana Lee Senior Legal Counsel Investment Management Phone: 416-593-2382 blee@osc.gov.on.ca
Autorité des marchés financiers Sahra Badrudin Senior Analyst Investment Products Supervision Phone: 514-395-0337, ext. 4427 sahra.badrudin@lautorite.qc.ca	Marie-Aude Gosselin Senior Analyst Investment Products Oversight Phone: 514-395-0337, ext. 4456 marie-aude.gosselin@lautorite.qc.ca
Financial and Consumer Services Commission of New Brunswick Ray Burke Manager Corporate Finance Phone: 506-643-7435 ray.burke@fcnb.ca
Nova Scotia Securities Commission Jack Jiang Securities Analyst Phone: 902-424-7059 jack.jiang@novascotia.ca	Peter Lamey Legal Analyst Phone: 902-424-7630 peter.lamey@novascotia.ca

Technical questions about submitting your comments? Click here to contact the CSA Secretariat. Or alternatively please reach out to info@acvm-csa.ca.

CSA Notice and Request for Comment - Liquidity Risk Management

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Part 1: Proposed Amendments to National Instrument 81-102 Investment Funds and Proposed Changes to Companion Policy 81-102 Investment Funds

General Comments regarding the Proposed Amendments to National Instrument 81-102 Investment Funds and Proposed Changes to Companion Policy 81-102 Investment Funds

1. Do you have any comments pertaining to section 6.1.1 Liquidity Risk Management Framework?

2. Do you have any comments pertaining to section 6.1.2 Operational Requirements?

3. Do you have any comments pertaining to section 6.1.3 Oversight?

4. Are there any types of investment funds that should be carved out of the Proposed Amendments? Alternatively, are there any types of investment funds that should be carved out of certain requirements in the Proposed Amendments? Please explain.

5. Do you have any other comments pertaining to the Proposed Amendments and Proposed CP Changes?

Part 2: Consultation Paper on Liquidity Risk Management Tools, Liquidity Classification, and Regulatory Disclosure and Data

General Comments regarding the Consultation Paper on Liquidity Risk Management Tools, Liquidity Classification, and Regulatory Disclosure and Data

1. For investment funds that are reporting issuers, is there a need for the CSA to permit the use of LMTs that are not already currently permitted? Please explain, and if applicable, identify any specific LMTs that the CSA should permit the use of.

2. For IFMs of investment funds that are reporting issuers, have there been past situations in which one of your investment funds would have benefited from being permitted to use an LMT that is not already currently permitted? If so, please explain, including an explanation for why you did not apply for exemptive relief from the applicable securities regulatory authority to use the LMT.

3. Are there any LMTs that the CSA should not permit to be used by investment funds that are reporting issuers? If so, please identify the specific LMTs and explain.

4. Should the CSA be requiring investment funds that are reporting issuers to adopt LMTs, including by requiring that such investment funds adopt a minimum number of LMTs or for example, a minimum number of price-based LMTs? Please explain, and if applicable, identify any specific LMTs that the CSA should require investment funds that are reporting issuers to adopt.

5. Should the CSA expand the circumstances in which an investment fund that is a reporting issuer can suspend redemption rights without regulatory approval beyond the circumstances set out in subsection 10.6(1) of NI 81-102? If so, please explain and identify the circumstances.

6. Should the CSA increase the temporary borrowing limit beyond what is currently permitted under section 2.6 of NI 81-102? If so, please explain and identify any potential parameters around the increased temporary borrowing limit.

7. For investment funds that are reporting issuers, are there any LMTs that are not discussed in this Consultation Paper that the CSA should consider permitting or requiring the use of? Please explain.

8. Are there any types of investment funds that are reporting issuers that should: (a) be carved out of any requirements relating to LMTs; (b) be subject to different requirements relating to LMTs; or (c) not be permitted to use any specific LMTs? Please explain.

9. Do you agree with the four classification categories? If not, please explain.

10. Do you agree with including the settlement period in the timeline set out in each of the four classification categories? If not, please explain.

11. Should any of the four classification categories be revised to distinguish between the timeline required to readily dispose of and settle an asset during normal market conditions and the timeline required to do so during stressed market conditions? If so, please explain the distinction that should be made.

12. Do you agree with the potential change to the definition of illiquid asset? If not, please explain.

13. Are there other aspects of the current definition of illiquid asset that should be revised? If so, please explain.

14. Do you agree that IFMs should be permitted to use a classification method that groups together portfolio assets that have similar characteristics? If not, please explain.

15. Do you agree that the CSA should not prescribe the liquidity classification category of specific asset classes or asset types as part of the classification framework and should leave such classification to the IFM?

16. Do you agree with the examples of factors included above under “Factors”? If not, please explain why you disagree, and if there are other factors that should be included as examples, please indicate.

17. If the classification framework requires that the IFM take into account the reasonably anticipated trade size for a portfolio asset in classifying the portfolio asset, should the framework require that the entire holding of that portfolio asset be classified into a single liquidity classification category, or should it allow for different portions of that portfolio asset to be classified into multiple liquidity classification categories?

18. Do you agree with a minimum monthly frequency for the requirement to review the liquidity classification of each of the fund’s investments? If not, please explain.

19. Are there any types of investment funds that should be carved out of the liquidity classification framework or be subject to different liquidity classification requirements? Please explain.

20. Should liquidity profile information be disclosed in the Proposed Fund Report? Please explain and if applicable, identify the liquidity-related information that should be included in the Proposed Fund Report and the format in which it should be disclosed.

21. If the CSA permits or requires the use of LMTs that are not already currently permitted or required, should the CSA require that all information about LMTs be disclosed in a new, separate section of the prospectus relating to LMTs or in an existing section of the prospectus, such as the “Purchases, Switches and Redemptions” section of the simplified prospectus? Please explain.

22. Is there any other liquidity-related information that should be disclosed in the prospectus, fund facts or ETF facts? Please explain.

23. Do you agree with requiring that investment funds disclose on a confidential basis to the applicable securities regulatory authority the liquidity classification category of each investment held by the fund? Please explain.

24. If the answer to question 23 is yes, do you agree with a quarterly reporting frequency? Please explain.

25. Is there any other liquidity profile-related information that the CSA should require investment funds to report to securities regulatory authorities on a confidential and periodic basis? Please explain.

26. Should investment funds be required to publicly disclose the liquidity classification category of each investment held by the fund and if so, what would be the appropriate frequency and timing of such disclosure? Please explain.

27. Should investment funds that are not reporting issuers be subject to this periodic reporting requirement? Please explain.

28. Do you agree with requiring that investment funds promptly report to the applicable securities regulatory authority when the above liquidity-related events under “Confidential reporting to securities regulatory authorities” occur? Please explain.

29. Are there any other liquidity-related events for which the CSA should require prompt reporting to the applicable securities regulatory authority? Please explain.

30. Should the occurrence of any of the above liquidity-related events under “Confidential reporting to securities regulatory authorities” also require public disclosure beyond the current material change reporting requirements? Please explain.

31. Should investment funds that are not reporting issuers be subject to these liquidity-related event reporting requirements? Please explain.

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CSA Notice and Request for Comment - Liquidity Risk Management

Part 1: Proposed Amendments to National Instrument 81-102 Investment Funds and Proposed Changes to Companion Policy 81-102 Investment Funds

Part 2: Consultation Paper on Liquidity Risk Management Tools, Liquidity Classification, and Regulatory Disclosure and Data

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