However, the CAC believes that certain entities or persons who fall within these definitions may not possess the same level of investment sophistication and knowledge. The CAC recommends eliminating the above-mentioned definitions of permitted clients from the proposed Rule. The CAC welcomes a lessening in regulatory complexity, but not at the expense of compromising adequate investor protection. Full disclosure increases investor protection by providing information that is important to the investment process. The CAC has traditionally supported and promoted full disclosure of information.
Full disclosure advances fair, open, and transparent markets, which strengthens market integrity.
The CAC recommends that the OSC retain certain minimum disclosure requirements to close this gap. The CAC recommends that the OSC require non-residents to maintain the same books and records and to provide the same disclosures that it requires of residents who register as advisers in Ontario. The OSC should additionally require that the non-resident adviser's books and records be readily available to Ontario investors for inspection on request. The CAC strongly believes that the disclosure threshold should not be lowered for non-resident advisers at the risk of weakening investor protection. The Proposal requires an international adviser to maintain the same standards of fairness for the allocation of investment opportunities that is required of a resident investment counsel.