CSA Notice of Publication: Regulation to Amend Investment Fund Continuous Disclosure Regime

CSA Notice of Publication
Regulation to amend Regulation 81-101 respecting Mutual Fund Prospectus Disclosure Regulation to amend Regulation 81-102 respecting Investment Funds Regulation to amend Regulation 81-106 respecting Investment Fund Continuous Disclosure Regulation to amend Regulation 81-107 respecting Independent Review Committee for Investment Funds Changes to Policy Statement to Regulation 81-107 respecting Independent Review Committee for Investment Funds Modernization of the Continuous Disclosure Regime for Investment Funds January 22, 2026 Introduction The Canadian Securities Administrators (the CSA or we) are modernizing the continuous disclosure regime for investment funds (the CD Modernization Project). We aim to improve the quality of disclosure provided to investors and reduce the unnecessary regulatory burden of certain current investment fund continuous disclosure requirements under securities legislation. The objectives of the CD Modernization Project are to:

• replace the existing annual and interim Management Report of Fund Performance (MRFP) with a new
  annual and interim Fund Report (Workstream One);

• reference the term Fund Expense Ratio (FER), which combines the management expense ratio and the
  trading expense ratio of an investment fund, in the Fund Facts and the ETF Facts (Additional FER Initiative);

• provide exemptions from certain conflict of interest reporting requirements in securities legislation where
  other similar requirements are satisfied (Workstream Two);

• eliminate certain required class or series-level disclosures from investment fund financial statements
  (Workstream Three); and

• make revisions to the version of Form 81-101F1 Contents of Simplified Prospectus (Form 81-101F1) that
  came into force on January 6, 20221 (Additional SP Disclosure Initiative).
  Workstream Two, Workstream Three and the Additional SP Disclosure Initiative For Workstream Two, Workstream Three and the Additional SP Disclosure Initiative, we are adopting amendments to the following:

• Regulation 81-101 respecting Mutual Fund Prospectus Disclosure (Regulation 81-101);

• Regulation 81-102 respecting Investment Funds (Regulation 81-102);
  1 https://lautorite.qc.ca/fileadmin/lautorite/reglementation/valeurs-mobilieres/81-101/2021-10-07/2021oct07-rid-avis-publication-final￾acvm-en.pdf.

• Regulation 81-106 respecting Investment Fund Continuous Disclosure (Regulation 81-106);

• Regulation 81-107 respecting Independent Review Committee for Investment Funds (Regulation 81-107)
  (collectively, the Amendments); and making changes to:

• Policy Statement to Regulation 81-107 respecting Independent Review Committee for Investment Funds
  (the Policy Statement 81-107 Changes)
  In some jurisdictions, ministerial approvals are required for the implementation of the Amendments. Provided all ministerial approvals are obtained, the Amendments will come into force on, and the Policy Statement 81-107 Changes will take effect on, April 22, 2026 (the Effective Date). The text of the Amendments and the Policy Statement 81-107 Changes is published with this Notice and will also be available on the websites of the following CSA jurisdictions:
  www.asc.ca www.fcaa.gov.sk.ca www.mbsecurities.ca www.osc.ca www.lautorite.qc.ca www.fcnb.ca https://nssc.novascotia.ca Workstream One and Additional FER Initiative For Workstream One and the Additional FER Initiative, the CSA continues to work on a Fund Report that will be more streamlined and significantly less burdensome for investment fund managers (managers or IFMs) to prepare for reporting issuer investment funds, and more likely to be read and understood by investors compared to the MRFP. We expect to have a subsequent publication on Workstream One and the Additional FER Initiative at a later date. Substance and Purpose The purpose of the CD Modernization Project is to modernize the continuous disclosure regime governing investment funds by enhancing the utility of investment fund disclosure for investors while reducing regulatory burden for IFMs. The Amendments relating to Workstream Two replace the overlapping statutory reporting requirements2 for related party transactions with a new standardized form. The Amendments ensure clear, standardized disclosure of information relevant to select related party transactions and remove the requirement to file duplicative, more frequent reports, without impacting investor protection or efficiency of the markets. Consistent with International Financial Reporting Standards (IFRS), the Amendments relating to Workstream Three remove the requirement to prepare certain class or series-level disclosures in the Statement of Comprehensive Income, the Statement of Changes in Financial Position, and the notes to the financial statements. The Amendments eliminate the disclosure of multiple classes or series, which provided minimal utility for investors and were unduly burdensome for investment funds. The Amendments for the Additional SP Disclosure Initiative are in response to feedback received following the January 6, 2022 effective date of the amendments to Form 81-101F1. 2 The overlapping reporting requirements applied in all CSA jurisdictions except Manitoba, Quebec, Prince Edward Island, Yukon, the Northwest Territories and Nunavut.

Background
Reducing Regulatory Burden for Investment Funds On September 12, 2019, the CSA published Reducing Regulatory Burden for Investment Fund Issuers – Phase 2, Stage 1 (Project RID Publication for Comment).3 Comments on the Project RID Publication for Comment were summarized in final amendments and changes published on October 7, 2021.4 On January 14, 2019, the Ontario Securities Commission published OSC Staff Notice 11-784 Burden Reduction5 (OSC Staff Notice 11-784). The CSA considered comments received in response to the Project RID Publication for Comment and OSC Staff Notice 11- 784, as well as recommendations made by the Capital Markets Modernization Taskforce created by the Ontario government, as described in its final report published in January 2021. CSA Business Plan The CSA’s 2022-2025 Business Plan identifies delivering smart and responsive regulation protecting investors while reducing regulatory burden, as a strategic goal. 7 The CSA reviewed investment fund continuous disclosure requirements to identify areas that could be updated to benefit key stakeholders, primarily investors and investment funds. Within the scope of our review, we not only included continuous disclosure requirements outlined in Regulation 81-106, but we also considered select reporting requirements present elsewhere in securities legislation (e.g., provincial statutes or Regulation 81-102). While financial statements formed part of our review area, we focused on requirements in Part 3 (Financial Disclosure Requirements) of Regulation 81-106 that are not mandated by IFRS. Draft Amendments On September 19, 2024, the CSA published draft amendments to regulations (the Draft Amendments) and draft changes to policy statements (the Draft Changes) to modernize the continuous disclosure regime for investment funds. The publication also included specific questions for comment, including a question on related party transactions (the Related Party Transactions Question). The deadline to submit comments on the Draft Amendments was extended to January 31, 2025. Summary of Written Comments Received by the CSA Of the 26 comment letters we received on the Draft Amendments, 13 letters provided comments on Workstreams Two, the Related Party Transactions Question, Workstream Three, and the Additional SP Disclosure Initiative. We thank everyone who provided comments. A summary of the comments together with our responses are set out in
Annex A. The names of the commenters are also set out in Annex A.
Copies of the comment letters are posted on the websites of the Alberta Securities Commission at www.asc.ca, the Ontario Securities Commission at www.osc.ca, and the Autorité des marchés financiers at www.lautorite.qc.ca. Summary of Changes After considering the comments received, we have made some non-material changes to the Draft Amendments for Workstream Two. No changes were made to the Draft Amendments for Workstream Three and the Additional SP Disclosure Initiative. The changes are reflected in the Amendments that we are publishing with this Notice. As these changes are not material, we are not republishing the Amendments for a further comment period. The following is a summary of the changes made to the Draft Amendments for Workstream Two:
(a) Manager’s Report on Related Party Transactions 3 https://lautorite.qc.ca/fileadmin/lautorite/reglementation/valeurs-mobilieres/81-101/2019-09-12/2019sept12-81-101-avis-cons￾projet_rid-en.pdf. 4 https://lautorite.qc.ca/fileadmin/lautorite/reglementation/valeurs-mobilieres/81-101/2021-10-07/2021oct07-rid-avis-publication-final￾acvm-en.pdf. 5 https://www.osc.ca/sites/default/files/pdfs/irps/20191119_reducing-regulatory-burden-in-ontario-capital-markets.pdf. 6 https://files.ontario.ca/books/mof-capital-markets-modernization-taskforce-final-report-en-2021-01-22-v2.pdf. 7 https://www.securities-administrators.ca/wp-content/uploads/2022/10/2022_2025CSA_BusinessPlan.pdf.

We received comments that the reference to “any other related party to the investment fund” in the Draft Amendments would capture parties who may not be contemplated by the manager’s report on related party transactions. We have therefore removed “any other related party to the investment fund” from section 2.5 of Regulation 81-107. As a result, disclosure would be provided for transactions involving the investment fund and an “entity related to the manager”, as defined in section 1.3 of Regulation 81-107. In response to comments, we changed section 2.5 to remove the requirement to provide a brief description of any provision in securities legislation or any order made under securities legislation that imposes a requirement to provide disclosure about the transaction or to keep a record in respect of the transaction. As a result of this change and the change to s. 2.5 of Regulation 81-107 noted in the above paragraph, disclosure will be required for other types of transactions “involving the investment fund and an entity related to the manager” that are not identified in a report for which an annual SEDAR+ report filing is required. This would include, for example, inter-fund trades, principal trades in debt securities with a related dealer or fund-on￾related fund transactions for which a report is not required under Regulation 81-107 or Regulation 81-102. (b) Form 81-107A Conflict Reporting Form for Related Issuer Purchases We received comments stating that a related party transaction report is prepared over a period of time and it would be difficult to provide an accurate preparation date. As a result, we have removed the requirement to disclose the date on which the report was prepared. With respect to an investment in a debt security, we also received comments asking for the removal of the requirement to disclose each source of any independent quote or independent pricing used to determine the price per security in which the investment was made. Commenters indicated that there would be added burden on the manager to provide this information and the information would be of minimal utility to investors. Accordingly, we have removed this requirement. For greater clarification and in response to the comments received, the requirement to disclose the name of any related person that has received, or will receive, a “fee in respect of the investment made” was changed to require disclosure of the name of any related person that received, or will receive a fee, commission or any other form of compensation in respect of the investment made. Transition Period and Effective Date The Amendments will become effective on the Effective Date. There will be transition periods for the Amendments for both Workstream Two and Workstream Three. The Amendments relating to the Additional SP Disclosure Initiative will not have a transition period. (a) Workstream Two An investment fund is not required to comply with parts 2, 4 and 6 of Regulation 81-107 until January
1, 2027, if the investment fund complied with those parts as of April 21, 2026. The Amendments provide an exemption from section 2.5 of Form 81-106F1 Contents of Annual and Interim Management Report of Fund Performance for investment funds that comply with section 2.5 of Regulation 81-107. (b) Workstream Three An investment fund is not required to comply with the Amendments for Workstream Three until January 1, 2027, if the investment fund complied with sections 3.2 and 3.3 and subsection 3.6(1) of Regulation 81-106 as of April 21, 2026. Please see the Annex A for a summary of comments and CSA responses relating to the consultation question regarding the effective date of the Amendments and Policy Statement 81-107 Changes, as well as the contemplated exemptions.

Contents of Annexes
This Notice contains the following annex:
Annex A: Summary of Comments and CSA Responses
Questions
Please refer your questions to any of the following CSA staff:
Autorité des marchés financiers
Marie-Aude Gosselin
Senior Analyst
Investment Funds Oversight
Tel: 514 395-0337 ext. 4456
Email: Marie-Aude.Gosselin@lautorite.qc.ca
Marie-Claire Lassonde
Senior Analyst
Sustainable Finance and International Affairs
Tel: 514 395-0337 ext 4607
Email: Marie-Claire.Lassonde@lautorite.qc.ca
British Columbia Securities Commission
James Leong
Senior Legal Counsel
Corporate Finance
Tel: 604 899-6681
Email: jleong@bcsc.bc.ca
Michael Wong
Senior Securities Analyst
Corporate Finance
Tel: 604 899-6852
Email: mpwong@bcsc.bc.ca
Alberta Securities Commission
Jan Bagh
Senior Legal Counsel
Corporate Finance
Tel: 403 355-2804
Email: jan.bagh@asc.ca
Melissa Yeh
Legal Counsel
Corporate Finance
Tel: 403 355-4181
Email: melissa.yeh@asc.ca
Financial and Consumer Affairs Authority of Saskatchewan Heather Kuchuran Director Corporate Finance, Securities Division Tel: 306 787-1009 Email: heather.kuchuran@gov.sk.ca Manitoba Securities Commission Patrick Weeks Deputy Director Corporate Finance Tel: 204 945-3326 Email: patrick.weeks@gov.mb.ca Ontario Securities Commission Ritu Kalra Senior Accountant Investment Management Division Tel: 416 593-8063 Email: rkalra@osc.gov.on.ca Stephen Paglia Vice-President Investment Management Division Tel: 416 593-2393 Email:spaglia@osc.gov.on.ca

Irene Lee
Senior Legal Counsel
Investment Management Division
Tel: 416 593-3668
Email: ilee@osc.gov.on.ca
Financial and Consumer Services Commission of New Brunswick Ray Burke Manager Corporate Finance Tel: 506 643-7435 Email: ray.burke@fcnb.ca Nova Scotia Securities Commission Abel Lazarus Director Corporate Finance Tel: 902 424-6859 Email: Abel.Lazarus@novascotia.ca

ANNEX A
SUMMARY OF PUBLIC COMMENTS AND CSA RESPONSES ON THE DRAFT AMENDMENTS FOR WORKSTREAMS TWO AND THREE AND ADDITIONAL INITIATIVES RELATING TO THE SIMPLIFIED PROSPECTUS BACKGROUND This Annex summarizes the written public comments we received on the Draft Amendments for Workstreams Two (including the Related Party Transactions Question), Workstream Three and the Additional SP Disclosure Initiative and together with our responses to those comments. The comments and responses on the Draft Amendments for Workstream One and Additional FER Initiative will be published in a separate publication at a later date. We received 13 comment letters with comments on the Draft Amendments for Workstreams Two (including the Related Party Transaction Question), Workstream Three, and the Additional SP Disclosure Initiative. A list of commenters is provided at the end of this Annex. We have considered the comments received, and in response to the comments, we have made some non-material changes to the Draft Amendments. Any comments we received that were related to other CSA policy initiatives were forwarded to the respective CSA working groups.
TABLE OF CONTENTS

1. Workstream Two (including the Related Party Transaction Question)

2. Workstream Three

3. Additional SP Disclosure Initiative

4. List of Commenters

5. WORKSTREAM TWO (INCLUDING THE RELATED PARTY TRANSACTION QUESTION)
   Workstream Two
   Issue Comment Response
   Support One industry association and two IFMs expressed support for the proposals in Workstream Two. The industry association noted that this change, together with the reduced filing frequency, will reduce burden for market participants, and one IFM noted the streamlined reporting and reduced reporting frequency. The CSA thanks the commenters for their support. Burden Reduction One IFM noted that Workstream Two may involve some burden reduction, but that this would not represent a significant net burden reduction, considering that the commenter noted Workstream One will increase regulatory burden. The Ontario Securities Commission (OSC) prepared a detailed quantitative cost-benefit analysis of the Draft Amendments and Draft Changes as part of the local
   annex for the OSC’s
   publication for comment, and this included an analysis of Workstream One.
   The CSA remains of the view that while Workstream One may involve an initial increase in burden, this will be outweighed by the ongoing benefits of producing more streamlined disclosure. Item 3(1) of Draft Form 81- 107A Conflict Reporting Form for Related Issuer Purchases (Draft Form 81- 107A) Two industry associations were of the view that the requirement to provide the date on which the report was prepared (Item 3(1) of Draft Form 81-107A should be eliminated because:
   (a) it is not relevant or meaningful to investors; (b) related party transaction reports are prepared over a period of time and it would be difficult to provide an accurate preparation date. Another industry association commented that if the CSA intended that the date under this subsection (1) should be the date on which the report is filed on SEDAR+, then this should be clearly noted. We agree. The CSA has removed the requirement to provide the date on which the report was prepared. Disclosure of the financial year covered by the report is required. Item 4(h) of Draft Form 81- 107A One industry association was of the view that the requirement to, in the case of an investment in a debt security, list “each source of any independent quote or independent pricing used to determine the price per security in which the investment is made” (Item 4(h) of Draft Form 81-107A) should be eliminated because:
   (a) it does not have utility for the average investor; (b) the added burden for IFMs to provide the information is not justified by its minimal utility to investors. We agree. The CSA has removed the requirement to disclose each source of any independent quote or independent pricing used to determine the price per security in which the investment is made.

Issue Comment Response
Item 4(j) of Draft Form 81-
107A
Two industry associations suggested revisions to the reference to a fee in Item 4(j) of Draft Form 81-107A. One industry association suggested that the reference to “fee” should be replaced with a reference to “commission”, as IFMs would only know if a commission was paid in respect of the investment made and would not necessarily have insight into whether any other fees were paid. The other industry association commented that the CSA should clearly define the term “fee”, and note that this requirement would not apply to transactions involving fixed income securities, as there is no fee or commissions paid in such transactions by the IFM, only a spread (i.e., the price that dealer purchased the security and the price the dealer will sell such security). However, an IFM would not have access to any information relating to the “spread” in any event. The reference to “fee” is not new as it is currently referred to in Item 117(1)3 of the Securities Act (Ontario), in Form 38 of Regulation 1015 and the equivalent in the applicable CSA jurisdictions. In response to comments, however, we have revised the requirement to provide greater clarity of the requested disclosure. The requirement now seeks disclosure of the name of any related person that has received, or will receive, a fee, commission or other form of compensation. Related Party Transactions in Draft Form 81-107A One IFM commented that it did not have an objection to providing the reporting contained in Draft Form 81-107A but did not agree with the requirement under paragraph (k) of Item 4 of Draft Form 81-1017A that an investment fund disclose the dealer involved in a related party transaction, as it is not relevant to investors, is confidential, and is proprietary to an investment funds and IFMs. We thank the commenter for the comment. The CSA considers it appropriate for Form 81-107A Conflict Reporting Form for Related Issuer Purchases (Form 81- 107A) to provide some transparency concerning when a related dealer has been used to execute the transaction. Noting this and in consideration of the comment, we have removed the requirement to disclose the name of the dealer used to execute the transaction and replaced it with a requirement to specify only when a related dealer has been used to execute the transaction and the name of the related dealer. We consider this approach to be consistent with the goal of providing transparency in Form 81- 107A concerning related party transactions. One industry association was of the view that Draft Form 81- 107A should not require any more than what is required under existing reporting requirements, noting that information not currently provided in reports should not be required as its utility to average investors is questionable and producing it is burdensome. The intention of the new Form 81-107A is to ensure consistency across IFMs in the related party transaction disclosure that is provided by each fund. It is also meant to ensure consistency in the
disclosure of material items relevant to related party transactions. Several of the items included as requirements in Form 81-107A have been disclosed in various related party transactions reports

Issue Comment Response filed by certain IFMs to date or have been requirements for related party transaction disclosure under provincial securities legislation. In this context, the CSA does not consider disclosure of such items, now prescribed in Form 81-107A, to be burdensome. One investor advocate was of the view that the CSA should carry out research to determine if retail investors understand related party transactions disclosure, and if it is not understood, then such disclosure should be made easier to understand and more useful using research and investor testing. The CSA considers the disclosure requirements in new Form 81-107A and Manager’s Report on Related Party Transactions in the appendix to the independent review committee (IRC) annual report to securityholders (IRC Report to Securityholders) to be plain language, high-level and to strike the right balance between the complexity of related party transactions and general information about related party transactions in a manner that will, or may, be useful to investors. As such, we do not consider further research to be necessary at this time.

Question 9 - Related Party Transactions
The Draft Form 81-106A Contents of Annual and Interim Fund Report (Draft Form 81-106A) does not include a section requiring disclosure pertaining to related party transactions. Instead, a different requirement has been developed and added as an appendix (to be prepared by the IFM) to the annual report to securityholders that an investment fund’s IRC must prepare pursuant to section 4.4 of Regulation 81-107. This contrasts with the current Form 81-106F1 Contents of Annual and Interim Management Report of Fund Performance (Current Form 81-106F1) which includes a section entitled “Related Party Transactions” (see Item 2.5 of Part B of the Current Form 81-106F1). Please comment on whether this proposed approach to disclosure regarding related party transactions is an effective method of providing this information to investors while ensuring that the Fund Report contains the appropriate amount of information and is easy to navigate. Issue Comment Response Support Two investor advocates expressed support for the proposal to consolidate related party transaction disclosure into an
appendix to the IRC Report to Securityholders, saying that it
is practical and expedient. The commenters noted, however, that retail investors should be easily able to access it, either through cross-references in the Fund Report or clear paths on the designated website of an investment fund. The CSA thanks the commenters for the support. Noting the comments, however, we have not added a requirement for a cross￾reference to the appendix to the IRC Report to Securityholders to be included in the Fund Report or on a fund’s designated website. Our view is that the new appendix is as relevant as all other required disclosure and accordingly, does not warrant a cross￾reference. Further, we consider that the location of the new appendix will become more familiar to investors over time, making a cross-reference unnecessary. One investor advocate noted that disclosure on conflicts of interest should be easy for investors to find and understand. The commenter also noted that while it made some sense to move the MRFP related party transaction disclosure to the IRC annual reports, the CSA should carry out research to confirm how visible IRC annual reports to securityholders are to investment fund securityholders and how to improve their visibility and the extent to which investors can understand the information in them. The commenter also suggested that the CSA should consider requiring a link to the IRC Report to Securityholders in the Fund Report. Please refer to our response above. One IFM noted that the ability to summarize related party transactions in a single report is welcome regulatory burden reduction, although the commenter expressed some requested revisions to the requirements which are set out in this summary. The CSA thanks the commenter for the support. Proposed Location One industry association commented that given that the mandate of the IRC is to oversee the processes the IFM has in place to manage conflicts of interest, they did not believe this information should be added to the IRC Report to Securityholders. The goal of locating the Manager’s Report on Related Party Transactions in an appendix to the IRC Report to Securityholders is to streamline the MRFP while ensuring no loss of relevant information concerning related party transactions and conflicts of interest.

Issue Comment Response
The effect of the change will be to locate specific information relevant to conflict of interest matters pertaining to the fund in one location instead of multiple locations. Effectively, the IRC Report to Securityholders will continue to be a separate report from the IRC. The Manager’s Report on Related Party Transactions in an appendix to the IRC Report to Securityholders will be a separate report from the perspective of the fund manager. “Related Party to an Investment Fund” Definition One industry association and 4 IFMs noted that the draft amendments added a new definition of “related party to an investment fund” through the draft subsection 2.5(2) of Regulation 81-107, and identified the following concerns:
(a) the new definition of “related party to an investment fund” may create a broader definition of “related party”; (b) the existence of the term “entity related to the manager” in Regulation 81-107, which is also used with “related parties” in Regulation 81-106, creates a need to clarify or align these three variations of definitions; (c) the draft amendments expand the scope of the definition of “related party to an investment fund” and may cause confusion, as the definition is contained in both the CPA Canada Handbook and the Draft Amendments to Regulation 81-107; (d) this addition would not reduce regulatory burden to IFMs. If the proposal is adopted, firms will need additional time to review the requirements and to make any necessary changes to their IRC reporting processes; (e) the introduction of the defined term “party related to the investment fund” introduces unnecessary complexity given that Regulation 81-107 currently contains a definition of an “entity related to the manager”; (f) the CSA should maintain the “existing definition” which is in line with the CPA Canada Handbook We thank the commenters for the feedback. In response to the comments, we have removed the reference in subsection 2.5(2) of Regulation 81-107 to “related party to an investment fund” and replaced it with a reference to the defined term of an “entity related to the manager” as contemplated by section 1.3 of Regulation 81-107. We expect this change to provide greater clarity on which entity or entities, in connection with the investment fund and its related party transactions, are captured by the reporting requirements of
section 2.5 of Regulation 81-
107.
New Requirement to
Disclose Inter-Fund Trades
One industry association was of the view that Draft Form 81- 107A introduces a new requirement to disclose inter-fund trades. The commenter noted that the proposed requirement appears to be more onerous than current practices and it is unclear how this additional disclosure is relevant or beneficial to investors, given that Regulation 81-107 and the independent review committee framework already governs such trades and imposes a robust compliance standard. To ensure complete disclosure of related party transactions, the Manager’s Report on Related Party Transactions in an appendix to the IRC Report to Securityholders does require high-level disclosure of any transaction involving the investment fund and an entity related to the manager for which a report is or is not filed on SEDAR+. The latter would include inter-fund trades. We consider this

Issue Comment Response disclosure to be appropriate and to provide sufficient transparency concerning related party transactions and any related reports that disclose details of related party transactions. Form 81-107A requires disclosure of the particulars of related party transactions contemplated pursuant to sections 6.2, 6.3 and 6.4 of Regulation 81-107, none of which contemplate inter-fund trades. Eliminate Requirement in Subparagraph 2.5(1)(c)(ii) to Provide Brief Description One industry association and three IFMs recommended removing the requirement under subparagraph 2.5(1)(c)(ii) of Regulation 81-107 to provide a brief description of any provision in securities legislation or any order made under securities legislation that imposes a requirement to provide disclosure about the transaction or keep a record in respect of the transaction. Commenters submitted that the requirement is more burdensome than the requirements of the Current Form 81-106F1 and that the requirement is not relevant to investors, and does not provide any investor benefit. We agree with the commenters. Accordingly, we have removed the requirement in subparagraph 2.5(1)(c)(ii) of Regulation 81-107 and maintained the requirement to provide a brief description of the type of transaction not otherwise covered by the requirements in paragraph 2.5(a). Eliminate or Modify Related Party Transactions Disclosure Three industry associations and three IFMs were of the view that the requirement to prepare the related party transactions disclosure in the MRFP should be eliminated entirely instead of being relocated to an appendix to the IRC Report to Securityholders because:
(a) related party transactions disclosure is a requirement in the financial statements under IFRS (b) the disclosure in the financial statements is a more effective way of providing related party transactions information to investors; (c) the function of the IRC is to report on processes in place and it is misplaced to relocate the related party transactions disclosure to an appendix of the IRC Report to Securityholders; (d) this disclosure should be incorporated into the financial statements, where it is already largely addressed under IFRS, as IFRS requires substantive related party transactions to be disclosed and made publicly available in the financial statements, rendering duplication in another document unnecessary; also, related party transactions are not typically a high-priority concern for readers of the MRFP; (e) the information is available in the financial statements and repeating it in an appendix is redundant and increases regulatory burden. However, if it is to be moved into an appendix, the commenter suggests keeping the disclosure in boilerplate form The commenters also noted that if the CSA chose to maintain the disclosure, it should maintain existing related party disclosure requirements in Part B, Item 2.5 of the existing MRFP instead of making draft amendments to Regulation 81-107. The CSA takes note of the comments indicating that disclosure of related party transactions in financial statements is sufficient to make unnecessary the relocation of such disclosure from the MRFP to an
appendix to the IRC Report
to Securityholders.
Our view is that related party transaction disclosure in the financial statements is made for, and pursuant to, IFRS. Further, we understand that much of the related party transaction disclosure in financial statements occurs in the notes to the fund’s financial statements. Among the goals of moving the related party disclosure from the MRFP to an
appendix to the IRC Report
to Securityholders is to ensure that relevant disclosure on related party transactions for securities law purposes, is in one general location. Further, the approach taken avoids the need to create a separate filing category on

Issue Comment Response
SEDAR+ for specifically, the
Manager’s Report on
Related Party Transactions.
The IRC Report to
Securityholders and the
Manager’s Report on
Related Party Transactions in an appendix to the IRC Report to Securityholders will allow the IRC and the IFM to have separate forums in which to discuss related party transactions. We do not consider this approach to be burdensome, but rather to provide appropriate transparency to investors and stakeholders seeking such information. Disclosure in Financial Statements One IFM had no objection to moving related party transaction reporting to another regulatory reporting document, however, related party transaction reporting may already be provided in the financial statements of an investment fund, and it may be superfluous to disclose them in the IRC Report to Securityholders. Please refer to our response above.

Question 18 - Additional Disclosure Elements
The Draft Form 81-107A will serve as a new, standardized form to be used for the filing of related party transaction reports under subsections 6.2(2), 6.3(3) and 6.4(2) of Regulation 81-107. The types of transactions to which the Draft Form 81- 107A applies, include purchases by an investment fund but not transactions where the investment fund took part in the sale of securities. Please comment on whether any stakeholders would be disadvantaged by sale information being left out of the Draft Form 81-107A. If any stakeholders are identified, please provide details on how they would use the sale information, if provided. Issue Comment Response No Stakeholders Disadvantaged by Leaving Out Sale Information Two industry associations and one law firm did not believe any stakeholders would be disadvantaged by sale information being left out of Draft Form 81-107A, with one industry association specifically noting that the proposals would not have a negative investor protection impact. Both industry associations were also of the view that it is likely that most IFMs do not report such information, either due to exemptive relief issued to them or through codified exemptive relief. The CSA notes the commenters’ views.

2. WORKSTREAM THREE
   Issue Comment Response
   General Comments One IFM, one law firm and three industry associations expressed support for the Workstream Three proposals, noting that there will be burden reduction without negatively impacting investors. The CSA thanks the commenters for their support. Impact of IFRS 18 (Presentation and Disclosure in Financial Statements)

Two industry associations noted that the impact of IFRS 18 should be considered with respect to the Draft Amendments. One of the industry associations noted that this approach would reduce burden and eliminates the need for subsequent revisions to the Fund Report after IFRS 18 comes into effect. The other industry association noted that further amendments to Part 3 of Regulation 81-106 may be warranted to eliminate potential inconsistencies with IFRS 18 as the Draft Amendments seek to eliminate class/series￾level performance data, but IFRS 18 may require this information. The commenter also noted that management￾defined performance measures may need to be incorporated into financial statements as a result of IFRS 18. One industry association requested that any changes made to the required disclosure be aligned with the timing of the new IFRS rules that will come into force on January 1, 2027. The CSA is not aware that the IFRS 18 requirements would require the inclusion of class- or series-level disclosures that will be eliminated as part of Workstream Three. The CSA is also of the view that further modifications to Part 3 of Regulation 81-106 arising from the implementation of IFRS 18 are not currently warranted. See the earlier response. The January 1, 2027, effective date of the Workstream Three amendments will align with the timing of the implementation of IFRS 18. Website Disclosure of Statement of Investment Portfolio One industry association expressed support to allow IFMs to provide Statement of Investment Portfolio disclosure on their designated website. The commenter also noted that most investors could access this information on a fund company’s website, and providing access instead of delivery of these reports would reduce regulatory burden for IFMs. The scope of review for this initiative did not include any delivery requirements. On September 27, 2022, the CSA published draft amendments and changes to implement an access￾based model for investment fund reporting issuers. Work on that initiative is ongoing. The delivery-related comments received in response to the Draft Amendments and Draft Changes have been provided to the CSA working on the access-based model for reporting issuer investment funds.

Question 19 - Stakeholders that would Benefit from Maintaining Disclosure As part of the Draft Amendments for this Workstream, we are proposing to eliminate certain class- or series-level disclosure requirements under Part 3 of Regulation 81-106 that are not required by IFRS. Please comment on whether any stakeholders would benefit from these disclosure requirements remaining in place. If any stakeholders are identified, please provide details on how they currently use such information and comment on whether any alternative sources of information are available. Issue Comment Response Support One industry association and one investor advocate indicated that there are not any significant concerns with the proposal to eliminate certain class or series level disclosure. Two IFMs and one law firm were of the view that the disclosure of certain class- and series- level disclosure is not useful to investors and stakeholders would not benefit from these disclosure requirements remaining in place. The elimination of this disclosure would assist with the readability and overall utility of a fund’s annual financial statements and interim financial reports. One IFM suggested that the CSA remove the disclosure requirements on an expedited basis, ahead of full implementation of its proposals. One investor advocate noted that while complexity is reduced by eliminating the class or series-level disclosure requirements, there is a risk of limiting transparency that may be to the detriment of retail investors who benefit from such disclosure. The commenter suggested that the disclosure should be retained elsewhere. The CSA notes the commenters’ views and submissions. The CSA is publishing the final amendments with respect to Workstream Two, Workstream Three and the Additional Initiative relating to the simplified prospectus, on an expedited basis, ahead of the final amendments for Workstream One. The CSA is of the view that the class or series level disclosures being eliminated from the Statement of Comprehensive Income and the Statement of Changes in Financial Position are of minimal utility to investors and unduly burdensome for investment funds to prepare. As such, the CSA is of the view the requirements should not be reproduced elsewhere. The CSA also notes with respect to the class or series level disclosures being eliminated from the notes to the financial statements, that class- or series-level disclosure regarding sales charges and management fees is available in other regulatory documents, such as the prospectus, the Fund Facts and the ETF Facts.

3. ADDITIONAL SP DISCLOSURE INITIATIVE
   Issue Comment Response
   No comments received.

4. LIST OF COMMENTERS

5. Borden Ladner Gervais LLP

6. Canada Life

7. Canadian Independent Finance and Innovation Counsel Inc.

8. Canadian Association of Retired Persons

9. Desjardins

10. FAIR Canada

11. Fidelity Investments Canada ULC

12. IGM Financial Inc.

13. Invesco Canada Ltd.

14. Investment Industry Association of Canada (now, Canadian Forum for Financial Markets)

15. Harvey S. Naglie

16. Portfolio Management Association of Canada

17. The Investment Funds Institute of Canada (now, Securities and Investment Management Association)