The Canadian Securities Administrators (CSA) has issued an update on proposed amendments to modernize the continuous disclosure requirements for non-investment fund reporting issuers published for comment in May 2021 (The Proposed Amendments).
The Proposed Amendments would streamline and clarify certain disclosure requirements for the management’s discussion and analysis (MD&A) and the annual information form (AIF). They would also combine interim and annual financial statements, MD&A, and, where applicable, the AIF into one reporting document for each reporting period (called the interim disclosure statement or annual disclosure statement, as applicable).
Following the publication of the Proposed Amendments, the CSA published in April 2022 a proposed access model for prospectuses and certain continuous disclosure documents for non-investment fund reporting issuers (the Proposed Access Model). The Proposed Access Model was generally well received by commenters. Guided by their feedback, CSA staff are considering further ways to the improve the access model. The CSA anticipates publishing a revised access model for continuous disclosure. The regulator expects that the final access model would apply to the proposed annual and interim disclosure statements. Until that time, CSA staff do not anticipate implementing any amendments that would introduce the annual and interim disclosure statements.
In deciding on the timing for implementing any of the continuous disclosure modernization proposals, the CSA staff advise they will ensure reporting issuers are provided with sufficient time to transition to any new forms and requirements.
For more information, please call Barbara Hendrickson at BAX Securities Law (647) 403-4606.
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