2019-02-07
The Canadian Securities Administrators issued this notice to clarify filing and fee obligations for Form 45-106F1 regarding exempt distributions involving fully managed accounts. Issuers and underwriters must generally file the form and pay fees based on the location of the trust company or adviser acting as principal, except in Manitoba and Quebec where requirements are triggered by the beneficial owner's location. Saskatchewan applies a distribution-based filing rule, though blanket relief waives requirements when the managing entity is not located in the province.