Regulatory Alerts2026-04-09
CSA Notice of Consultation: Draft Regulation to Amend Regulation 55-104 on Insider Reporting for Investment Funds and Structured Products
The Canadian Securities Administrators are proposing amendments to Regulation 55-104 to clarify insider reporting requirements for transactions involving investment funds and certain structured products. The draft regulation explicitly excludes investment funds and structured products like ADRs and CDRs from the exemption in paragraph 9.7(g), ensuring that reporting insiders cannot rely on this provision for such holdings. This change addresses recent market developments, including single-issuer exchange traded funds, to ensure that economic exposure equivalent to direct security ownership triggers appropriate insider reporting obligations.
Share