January 1, 2024 to December 31, 2024
The activities of the CSA IAP, or the Panel, during the year reflected the panel members’ commitment to deliver on its mandate to represent the interests of retail investors by providing independent advice to the CSA. The IAP provides insights and feedback to proposals before they are made public, so that projects benefit from the panel’s advice and expertise from inception.
In 2024, the IAP continued to provide advice on CSA initiatives that focused on investor protection, improved disclosure and trends that impact Canadian retail investors.
Proposed Framework for an Independent Dispute Resolution Service with Binding Authority (OBSI)
Recognizing the critical importance of this initiative for investors, the IAP focused its efforts throughout the year on providing meaningful input to the OBSI project committee. The IAP consulted with stakeholders and investor advocates on dispute resolution in Canada. These discussions and the panel’s reflections on this topic resulted in the IAP’s first public comment letter. The letter expressed support for the proposed framework and highlighted the need for binding authority, underscoring that the initiative should improve the fairness of our capital markets.
Proposed Amendments to modernize Continuous Disclosure Regime for Investment Funds
In September 2024, the CSA published for comment a series of proposed amendments aimed at modernizing the continuous disclosure regime for investment funds. These proposals are designed to provide investors with more focused and valuable disclosure while reducing the regulatory burden on investment fund managers. The proposed changes are based on behavioural research and testing that identify how to improve the understanding and engagement of the Fund Report by investors. Of critical importance for the IAP was ensuring that these changes reflect a more systematic and purposeful approach to clear communication that can simultaneously make mandated disclosure and investor education more effective. Throughout the comment period, the IAP exchanged with the project committee and provided recommendations in support of these improved disclosure efforts.
Proposed Access Model for Certain Continuous Disclosure Documents of Corporate Issuers
In line with improved access to continuous disclosure documents for retail investors, the IAP worked closely with the project committee responsible for the Proposed Access Model for Certain Continuous Disclosure Documents of Corporate Issuers. Following the initial comment period, the IAP became involved in this initiative to support the project committee’s efforts to address the comments received from investor advocates. Throughout this process, the IAP continuously provided guidance and recommendations that spoke to improved access to disclosure. In 2024, the IAP lent its expertise to test some of the functionalities of SEDAR+, a key component of the proposal. This was a good exercise, as the project committee was able to determine the different levels of usability based on the experience and the perspectives of the different panel members with the functionalities. The IAP’s contribution was acknowledged by the project committee in both the notice and news release when it officially published.
In a landscape where investors continue to search out information outside trusted sources, and growing trends in online misleading information, the IAP continues to actively provide important feedback to CSA projects. The panel continues to emphasize the importance of improved disclosure, and clear communication with the investing audience that ultimately serves the CSA’s investor protection mandate.
