As
we discussed recently, Canadian registration
rules were amended in July with the stated intention of
improving the day-to-day operation of the rules for both
industry and regulators. Of interest to investment fund
managers, the amendments revised the guidance in the Companion Policy to NI 31-103 Registration
Requirements, Exemptions and Ongoing Registrant
Obligations regarding how the investment fund
manager registration requirement applies to various fund
structures. Specifically, section 7.3 of the Companion Policy now
states as follows:
* * * * * * * * * *
Investment fund complexes or groups with more than one
investment fund manager
Some investment fund complexes or
groups may have more than one entity within the fund complex that
can be considered as directing the business, operations or affairs
of an investment fund. For example, structures where investment
funds are organized as limited partnerships may have multiple
entities within the fund
