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CSA Proposes Amendment to Insider Reporting for Investment Funds and Structured Products

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Summary

The Canadian Securities Administrators published a notice and request for comment on a proposed amendment to Part 9 of National Instrument 55-104, clarifying insider reporting obligations for transactions involving investment funds and structured products such as structured notes, ADRs, and CDRs. The 60-day comment period closes June 8, 2026.

What changed

The CSA proposes amendments to Part 9 of National Instrument 55-104 to clarify insider reporting requirements for transactions involving investment funds and structured products, including structured notes, American Depositary Receipts (ADRs), and Canadian Depositary Receipts (CDRs) based on securities of the reporting insider's reporting issuer.

Reporting insiders, public companies, and investment fund managers should prepare to review their insider reporting policies and submit comments by June 8, 2026. The proposed clarification will affect how insiders report transactions in these financial instruments and may require updates to compliance procedures.

What to do next

  1. Submit comments on the proposed amendment by June 8, 2026
  2. Review insider reporting obligations for investment fund and structured product transactions

Archived snapshot

Apr 10, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

TORONTO – The Canadian Securities Administrators (CSA) today published a notice and request for comment on a proposed amendment to Part 9 of National Instrument 55-104 Insider Reporting Requirements and Exemptions.

The proposed amendment is intended to clarify the insider reporting regime applicable to transactions involving investment funds, and certain structured products, such as structured notes, American Depositary Receipts and Canadian Depositary Receipts, that are based on securities of the reporting insider’s reporting issuer.

The CSA welcomes feedback on the proposed amendment. The 60-day comment period closes June 8, 2026. Stakeholders are encouraged to submit their comments using the method set out in the notice, which is available on CSA members’ websites.

The CSA, the council of securities regulators of Canada’s provinces and territories, coordinates and harmonizes regulation for the Canadian capital markets.

For investor inquiries, please contact your local securities regulator.

For media inquiries, please contact:

Named provisions

Part 9 - Insider Reporting Requirements and Exemptions

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Last updated

Classification

Agency
CSA
Comment period closes
June 8th, 2026 (59 days)
Compliance deadline
June 8th, 2026 (59 days)
Instrument
Consultation
Legal weight
Non-binding
Stage
Consultation
Change scope
Substantive
Document ID
National Instrument 55-104, Part 9

Who this affects

Applies to
Public companies Investors
Industry sector
5231 Securities & Investments
Activity scope
Insider reporting compliance Investment fund transactions
Geographic scope
Canada CA

Taxonomy

Primary area
Securities
Operational domain
Compliance
Topics
Corporate Governance Financial Services

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