Overview Of Comments On The CSA's Exempt Market Proposals

Whereas the comments on the definition of securitized product and the prospectus disclosure proposals were quite limited and restrained, those on the proposed exempt market rules were both extensive and harshly critical. The general themes were common to most commentators. The proposed rules:

• are an over reaction to the failure of the third party sponsored ABCP market in Canada;
• focus unnecessarily on risks inherent in high risk structures such as those originated under the originate to distribute model or synthetic structures that either did not or no longer exist in Canada;
• inappropriately apply a one size fits all approach to the traditional securitization market; and