CSA Issue Relief From Newly Enacted "Canadian Permitted Client" Restrictions

Earlier this week, all CSA members except the OSC issued blanket orders to provide interim relief from the new restrictions on registration exemptions for international dealers and international advisers found in the July 2011 amendments to NI 31-103. As such, the investment dealer and international adviser exemptions are once again generally premised on whether a client is a "permitted client" rather than a "Canadian permitted client". As Ontario securities law does not permit the OSC to issue an order of this nature, OSC Staff have confirmed that they will not enforce the "Canadian permitted client" restrictions provided that, when relying on the exemption, an international dealer or international adviser