SIFMA provides comments to the Canadian Securities Administrators’ (CSA) on the CSA’s Notice of and Request for Comment on Proposed Amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations dated December 5, 2013 (CSA Notice).

SIFMA shares its views on certain of the proposed amendments to NI 31-103, in particular:

• the significant limitations being proposed for the permitted activities of Exempt Market Dealers (EMDs) and Restricted Dealers (RDs_;
• the regulatory status of prime brokerage activities provided by Broker-Dealers registered under the EMD category;
• the regulatory status of inter-listed securities in the context of the definition of “foreign security”; and
• the regulatory consequences of new sections for firms that are concurrently registered as dealers and/or advisers and relying on exemptions from the dealer and/or adviser registration requirements.

SIFMA is not in favor of the proposed amendments set forth in the CSA Notice. Nonetheless, if the proposed amendments are implemented, SIFMA believes that there are changes that should be made in the context of certain activities and inter-listed securities.