Davies Comments on Proposed Amendments to NI 81-102 Investment Funds
Summary
Davies Ward Phillips & Vineberg submitted a comment letter to the Canadian Securities Administrators responding to proposed amendments to National Instrument 81-102 Investment Funds regarding liquidity risk management requirements. The letter raises concerns about extending these requirements to private investment funds, arguing that such funds already receive appropriate oversight through registration requirements under NI 31-103, and advocates for a more tailored, principles-based regulatory approach.
What changed
Davies submitted a comment letter responding to CSA's November 2025 consultation on proposed amendments to NI 81-102 that would extend liquidity risk management requirements to private investment funds. The firm argues this represents regulatory overreach, as private funds already fall under appropriate oversight via NI 31-103 registration requirements. Davies advocates for a principles-based, tailored approach rather than a blanket extension of the rules.
Affected parties managing or investing in private investment funds should monitor the CSA's response to industry comments. Fund managers previously unaffected by NI 81-102's liquidity provisions may face new compliance obligations if these amendments are adopted in their current form. The CSA's handling of comments suggesting regulatory overlap could signal a narrower final rulemaking scope.
What to do next
- Monitor CSA final rulemaking on NI 81-102 liquidity requirements
- Review liquidity risk management obligations if you manage private investment funds
- Assess whether existing NI 31-103 oversight adequately addresses liquidity concerns
Archived snapshot
Apr 9, 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.
April 9, 2026
Davies Comments on Proposed Amendments to National Instrument 81-102 Investment Funds
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Davies recently submitted a comment letter in response to public consultations initiated by the Canadian Securities Administrators (CSA) regarding proposed amendments to National Instrument 81-102 Investment Funds concerning liquidity risk management, as published by the Canadian Securities Administrators on November 27, 2025, including the concepts discussed in the consultation paper.
The comment letter, prepared by Jean-Philippe Joyal and Adam Curran, delves into the implications of extending liquidity risk management requirements to private investment funds, raising key concerns about regulatory overreach into a market segment that is already subject to appropriate oversight through registration requirements under National Instrument 31-103. It further explains why Davies advocates for a more tailored, principles-based approach to regulation.
Download the comment letter to learn more about this intersection of law, finance and policy.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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