September 8, 2015 may go down in history as the "day the
wrappers died" – for U.S. broker-dealers who sell
foreign securities into Canada on a private placement basis, for
the Canadian investors who purchase these securities and for the
lawyers who advise them.
On June 25, 2015, the Canadian Securities Administrators
announced that rule amendments will come into force on September 8,
2015 that will not only codify certain discretionary "wrapper
relief" orders granted in 2013, but also significantly expand
the scope of that relief to eliminate virtually all the lingering
issues created by those orders. The net result is that the
vast majority of U.S. registered and non-registered offerings of
"eligible foreign securities" after September 8, 2015 can
be extended into Canada using only the U.S. offering document
without the need for a Canadian "wrapper".
