The update regulates insider reporting for investment funds and structured products (structured notes, ADRs, CDRs), which are investment vehicles managed by non-depository institutions to help clients manage assets—core Investment Services territory.
Structured products and notes have fixed income characteristics as they provide alternative economic exposure through debt-like instruments, though the primary focus is on the investment fund and structured product framework rather than pure bond trading.
Specialism
The proposed amendment directly addresses insider reporting obligations for transactions in investment funds and structured products, which falls under market conduct and insider trading regulation.
Mandatory inheritance: Market Abuse/Market Conduct is a child of Supervision, so Supervision must be raised as the secondary tag.
2026-04-10 15:28:06·ataylor@vixio.com
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TITLE: Canadian Securities Administrators Propose Amendment to Insider Reporting Requirements for Investment Funds and Structured Products
BODY:
On April 9, 2026, the Canadian Securities Administrators (CSA) published a proposed amendment to Part 9 of National Instrument 55-104 Insider Reporting Requirements and Exemptions (NI 55-104) for a 60-day comment period.
The proposed amendment clarifies the insider reporting regime applicable to transactions involving investment funds and certain structured products, including structured notes, American Depositary Receipts (ADRs), and Canadian Depositary Receipts (CDRs) based on securities of a reporting insider's reporting issuer. The amendment follows the launch of single-issuer exchange-traded funds in the Canadian market in August 2025 and the subsequent introduction of funds tracking major Canadian reporting issuers, as well as structured products providing alternative economic exposure to reporting issuers.
The proposed amendment would exclude investment funds from the exemption in paragraph 9.7(g) of NI 55-104, ensuring that the exemption in paragraph 9.7(f)—which requires that securities of the reporting issuer do not form a material component of the investment fund's market value—becomes the relevant exemption for acquisitions or dispositions of investment fund securities by reporting insiders. Additionally, the amendment clarifies that paragraph 9.7(g) does not apply to certain structured products where the value or market price is derived from, referenced to, or based on an underlying security that includes a reporting issuer's security or a related financial instrument as a material component.
The comment period closes on June 8, 2026. Submissions can be made through the CSA consultation portal at https://www.securities-administrators.ca/consultations/csa-notice-and-request-for-comment-proposed-amendment-to-national-instrument-55-104-insider-reporting-requirements-and-exemptions-relating-to-investment-funds-and-certain-structured-products/. All comments received will be published on the websites of the Alberta Securities Commission, Autorité des marchés financiers, and Ontario Securities Commission.