On July 5, 2012, the Canadian Securities Administrators
published final versions of Multilateral Instrument 32-102
Registration Exemptions for Non-Resident Investment Fund
Managers (MI 32-102) and Multilateral Policy 31-202
Registration Requirements for Investment Fund Managers (MP 31-202) relating to registration
requirements and exemptions for investment managers headquartered
in Canada (Canadian investment fund managers).
The final versions of MI 32-102 and MP 31-202 follow earlier
proposals that were published in February 2012 and discussed in a
February 17, 2012
Osler Update.
The Exemption-Based Jurisdictions will adopt MI 32-102. All
other provinces and territories (the Policy-Based Jurisdictions),
including New Brunswick, which in February had supported MI 32-102,
will adopt MP 31-202. Regrettably, and despite the urgings of many
of the commenters on the February proposals, including Osler, there will not be one harmonized
approach in Canada to registration
