Yet More Enhancements Proposed For Private Placement Reporting

The Canadian Securities Administrators (CSA) have managed to harmonize their differences for reporting prospectus-exempt distributions since their earlier proposals in February and March 2014. They have now proposed a common form that would apply across Canada for both investment funds and other types of issuers. While the new proposal drops some of the information detail requirements originally proposed in 2014, it also adds new required information.

The original proposals were discussed in our April 2014 Blakes Bulletin: Haven't You Heard? It's All Being Changed – New Proposals to Private Placement Regime. One of the principal concerns then was that the different provinces' proposals could result in up to four different versions of a private placement report. This was heavily criticized and the CSA have made significant effort to achieve a single harmonized form. On the other hand, like most products with many cooks, the end result tends to be enhanced rather than