CSA Proposes Amendment to Insider Reporting Requirements for Investment Funds and Structured Products
Summary
The Canadian Securities Administrators published a notice proposing amendments to Part 9 of National Instrument 55-104 to clarify insider reporting requirements for investment fund transactions and structured products such as notes, American Depositary Receipts, and Canadian Depositary Receipts based on reporting insiders' securities. The 60-day comment period closes June 8, 2026.
What changed
The CSA proposes amendments to clarify insider reporting obligations for transactions involving investment funds and structured products (notes, ADRs, CDRs) that are based on securities of the reporting insider's reporting issuer. This clarification affects how insiders must report indirect holdings and transactions in these instruments under NI 55-104 Part 9.
Public companies, insiders, and investment fund managers should review the proposed amendments to understand how their insider reporting obligations may be affected when dealing with investment funds or structured products linked to their reporting issuer's securities. Stakeholders are encouraged to submit feedback during the 60-day comment period.
What to do next
- Review the proposed amendment to NI 55-104 Part 9
- Submit comments by June 8, 2026 using the method specified in the notice
- Assess impact on insider reporting obligations for investment fund and structured product transactions
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Apr 12, 2026GovPing 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.
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CSA publishes proposed amendment to insider reporting requirements for comment
Apr 09, 2026
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:
Ilana Kelemen
Canadian Securities Administrators
[email protected]
Debra Chan
Ontario Securities Commission
[email protected]
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