The update addresses insider reporting requirements for investment funds, structured notes, ADRs, and CDRs—all investment vehicles and securities that fall within the Investment Services category's scope of asset handling and client asset management.
The structured products referenced (structured notes, ADRs, CDRs) have characteristics of fixed income or equity instruments depending on their underlying assets, but the primary focus is on the investment fund and structured product reporting regime rather than a specific asset class.
Specialism
The proposed amendment clarifies insider reporting obligations for transactions involving investment funds and structured products, which directly relates to insider trading and market conduct regulation.
Mandatory inheritance: Market Abuse/Market Conduct is a child of Supervision, so Supervision must be raised as the secondary tag.
2026-04-10 15:40:40·ataylor@vixio.com
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TITLE: Canadian Securities Administrators Publishes Proposed Amendment to Insider Reporting Requirements
BODY:
On [date of publication], the Canadian Securities Administrators (CSA) published a notice and request for comment on a proposed amendment to Part 9 of National Instrument 55-104 Insider Reporting Requirements and Exemptions.
The proposed amendment aims to clarify the insider reporting regime applicable to transactions involving investment funds and certain structured products, including structured notes, American Depositary Receipts and Canadian Depositary Receipts, that are based on securities of the reporting insider's reporting issuer. The amendment addresses ambiguities in how insider reporting obligations apply to these investment vehicles, ensuring consistent application across Canada's capital markets. The CSA, which coordinates and harmonizes regulation for the Canadian capital markets across Canada's provinces and territories, is seeking stakeholder feedback to refine the proposed clarification before finalisation.
The 60-day comment period closes on June 8, 2026. Stakeholders, including market participants, investment fund managers, and other interested parties, are encouraged to submit their comments using the method set out in the notice, which is available on CSA members' websites. Comments should be directed to the relevant provincial or territorial securities regulator. For further information or clarification on the proposed amendment, stakeholders can contact the CSA or their local securities regulator.
**References:**
Canadian Securities Administrators: https://www.securities-administrators.ca/