Submissions

The Committee issues Submissions to the regulatory authorities to effect change.  A Submission may be published as a response to a request for comment, or on a proactive basis, when CIRI believes an issue has high importance to the IR profession.

Latest Submissions

CIRI Comments on Proposed Amendments to Multilateral Instrument 62-104 Take-Over Bids and Issuer Bids (MI 62-104) and changes to National Policy 62-203 Take-Over Bids and Issuer Bids (NP 62-203) June 29, 2015
We commend the CSA for proposing harmonized amendments to the take-over bid regime that put unsolicited or ‘hostile’ bidders and target companies on a more equal footing. We recognize the effort expended to arrive at this alternative co-ordinated proposal that responds to comments from a broad section of market participants following the publication of the initial CSA and AMF proposals in 2013. Different regulatory initiatives seeking to achieve similar outcomes can be confusing, costly and potential conflicting for issuers.
CIRI Comments to OSC on Application for Recognition of Aequitas Innovations Inc. and Aequitas Neo Exchange Inc. as an Exchange September 5, 2014
The Canadian Investor Relations Institute (CIRI), has commented to the OSC on the
application for recognition of Aequitas Innovations Inc. and Aequitas Neo Exchange Inc. as an Exchange. CIRI's comments relate to the investor relations requirements in the Listing Manual, specifically in Part II, Section 2.02 Minimum Listing Standards – General, Sub-section (5) Analyst Coverage/Investor Relations Requirements.
CIRI Comments on CSA Proposed Amendments to Form 58-101F Disclosure Requirements Regarding Women on Boards and in Senior Management September 2, 2014
The Canadian Investor Relations Institute (CIRI) today forwarded a submission to the Canadian Securities Administration (CSA) in response to their proposed amendments for disclosure of women on boards and in senior management. This submission reiterates our previously submitted position.
CIRI Comments on Proposed National Policy 25-201 Guidance for Proxy Advisory Firms July 22, 2014
The Canadian Investor Relations Institute (CIRI) today submitted comments to the Canadian Securities Administrators (CSA) in response to CSA Consultation Paper
25-­-401: Potential Regulation of Proxy Advisory Firms.
CIRI Comments on the Consultation on the Canada Business Corporation Act May 15, 2014
The Canadian Investor Relations Institute (CIRI) today forwarded a submission in response in response to the request for comments on the above reference Industry Canada Consultation Paper.

Archived Submissions

CIRI Comments on Proposed Amendments to Multilateral Instrument 62-104 Take-Over Bids and Issuer Bids (MI 62-104) and changes to National Policy 62-203 Take-Over Bids and Issuer Bids (NP 62-203) June 29, 2015
We commend the CSA for proposing harmonized amendments to the take-over bid regime that put unsolicited or ‘hostile’ bidders and target companies on a more equal footing. We recognize the effort expended to arrive at this alternative co-ordinated proposal that responds to comments from a broad section of market participants following the publication of the initial CSA and AMF proposals in 2013. Different regulatory initiatives seeking to achieve similar outcomes can be confusing, costly and potential conflicting for issuers.

Recent Submission

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CIRI Comments on CSA Proposed Amendments to the Early Warning System

CIRI has submitted comments to the CSA on proposed amendments NI 62-103 Early Warning Systems and Related Take-Over Bid and Insider Reporting Issues published in March.

CIRI's submission illustrates that Canada's early warning threshold are too high and includes multiple recommendations to the CSA including a reduction in the beneficial ownership threshold.

Click here to learn more.

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