Originally published in Blakes Bulletin on Securities
Regulation, April 2009
The Canadian Securities Administrators (CSA) have announced that
they expect to submit a final version of National Instrument 31-103
– Registration Requirements to their respective
commissions for approval in June 2009, with the intention of
publishing the rule in mid-July 2009. Assuming the necessary
approvals from government authorities in each jurisdiction, the new
rule will come into force at the end of September 2009.
The CSA have not released a new version of the proposed rule,
and so the version published in February 2008 remains the most
current publicly available version. However, it appears that the
CSA are not contemplating substantial changes from the February
2008 version – if they were, they would be required to
republish another version for comment, which is not the approach
that they have announced.
Therefore, assuming that the final version of the rule will be
substantially similar to the February 2008 draft, it is likely that
the new rule will provide some transitional relief to provide
market participants adequate time to make necessary changes to
satisfy any new requirements. Generally speaking, the February 2008
rule provided for six-month transition periods for this
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