2026-06-25
Changes to Policy Statement to Regulation 54-101 Respecting Communication with Beneficial Owners of Securities of a Reporting Issuer
The Canadian Securities Administrators issued this document to replace Section 4.1 of the Policy Statement to Regulation 54-101 regarding communication with beneficial owners. The revised text clarifies that beneficial owners use client response forms to specify their preferences for receiving materials and disclosing ownership information, while intermediaries must alert clients to the costs and consequences of these options. It further establishes that failing to return an annual request form for financial statements overrides standing instructions, unless the reporting issuer provides electronic access to the documents under Regulation 51-102.

CHANGES TO POLICY STATEMENT TO REGULATION 54-101 RESPECTING
COMMUNICATION WITH BENEFICIAL OWNERS OF SECURITIES OF A
REPORTING ISSUER
- Section 4.1 of Policy Statement to Regulation 54-101 respecting Communication with
Beneficial Owners of Securities of a Reporting Issuer is replaced by the following:
“4.1. Client Response Form
By completing a client response form as provided in Part 3 of the Regulation,
a beneficial owner gives notice of its choices concerning the receipt of materials and the
disclosure of ownership information concerning it. Pursuant to section 3.4 of the Regulation,
a beneficial owner may, by notice to the intermediary through which it holds, change any
prior instructions given in a client response form. Proximate intermediaries should alert their
clients to the costs and other consequences of the options in the client response form. Subject
to subsections 4.6(5.1) and 4.6(5.2) of Regulation 51-102 respecting Continuous Disclosure
Obligations (chapter V-1.1, r. 24), subsection 4.6(1) of that Regulation requires reporting
issuers to send annually a request form to the registered holders and beneficial owners of its
securities, other than holders of debt instruments, that the holders may use to request a copy
of the reporting issuer’s financial statements and MD&A. If a request form is sent under
subsection 4.6(1), a failure to return the request form or to specifically request a copy of the
financial statements or MD&A from the reporting issuer will override the beneficial owner’s
standing instructions under this Regulation in respect of the financial statements. However,
a beneficial owner’s standing instructions under this Regulation in respect of the financial
statements will not be overridden if a reporting issuer provides electronic access to the
documents under section 4.5.1 or 4.5.2 of Regulation 51-102 respecting Continuous
Disclosure Obligations.”.