2023-06-09
The Canadian Securities Administrators issued this policy statement to clarify the interpretation and application of Regulation 55-104, which consolidates insider reporting requirements and exemptions for reporting issuers. The document defines key terms such as reporting insider, beneficial ownership, and related financial instruments to ensure compliance with substantive legal obligations while prioritizing substance over form. It further explains the rationale for insider reporting, including deterring improper trading and preventing stock option backdating, and provides guidance on determining insider status based on access to material information and influence over the issuer.