Wrapper‎ Amendments Bring Relief — But Not For Everyone

Earlier this summer, the Canadian Securities Administrators (CSA) introduced a series of related regulatory amendments¹ (collectively, the Wrapper Relief Amendments) bringing much anticipated relief from onerous disclosure requirements for many foreign issuers offering their securities in Canada. The amendments, which came into force on September 8, 2015, were designed to avoid the requirement for a foreign issuer to prepare and deliver certain supplementary information to Canadian permitted clients (primarily institutions and ultra-high net worth investors) in the context of a private placement of securities. This disclosure was previously provided in the form of a "wrap" disclosure document (the Canadian Wrapper) attached to the front of the issuer's offering document.