2021-05-20
The Canadian securities regulators issued draft amendments to Policy Statement 54-101 to clarify the mechanisms for reporting issuers to communicate with beneficial owners of securities. The changes update the Client Response Form provisions to explicitly allow annual financial statements and MD&A to be included in an annual disclosure statement or report, aligning with the notice-and-access delivery model. Additionally, the amendments clarify that the timing rules for sending proxy-related materials do not restrict the later delivery of annual financial statements to beneficial owners, provided they are sent within the time limits applicable to registered holders.