A more efficient system is within reach—if we choose to build it
Canada’s investment regulatory system is built on a shared objective: protecting investors while fostering fair, efficient markets. Few would argue with that goal. But in practice, the system increasingly undermines efficiency, predictability, and investor outcomes.
Two issues illustrate this challenge clearly: how regulatory fees are set, and how fragmented our regulatory architecture is across the provinces. These issues affect costs borne by investors, deter firms’ ability to innovate, and weaken Canada’s competitive position as a place to build and scale investment businesses.
At SIMA, we believe these issues are connected. And more importantly, they are solvable.
- Fee setting needs transparency—and a longer view
Regulatory fees have been rising across jurisdictions. Set independently, their cumulative impact is significant—and rarely visible in full.
The recent Autorité des marchés financiers du Québec (AMF) fee consultation in addition to the British Columbia Securities Commission’s (BCSC) ETF fee increase announced in 2024 has brought this issue into sharp focus.
Just last week, the Ontario Securities Commission (OSC) published proposed amendments to its fee rules for public comment. The proposals point to a broader reassessment of fee structures, including efforts to enhance predictability and recalibrate how regulatory costs are distributed across market participants.
While these proposals will need to be reviewed closely, they underscore an important point: regulators across the country are grappling with the same fundamental questions about how fees are set, how they evolve over time, and how they affect market participation and investment outcomes.
In Quebec, proposed increases of up to 45 per cent for some investment fund filings were introduced without clear linkage to regulatory costs, service levels, or investor outcomes. This comes at a time when Quebec already has the highest investment fund regulatory fees in Canada and when the AMF itself has accumulated a substantial budget surplus.
This is not a Quebec only issue. Similar questions are being asked across the country as firms navigate multiple regulators, overlapping mandates, and an evolving—and often unpredictable—fee environment.
In BC, the proposed fee increase would have added an estimated $9 million in costs for fund companies in 2025. With ETF sales generally rising each year, the fee would be expected to rise over time.
That is why SIMA’s message to the AMF, and now more broadly to regulators nationally, has been consistent: fee increases must be grounded in transparency, predictability, and cost discipline.
Transparency starts with explaining how fees are set, and why. Predictability requires multi year frameworks that allow our member firms to plan, invest, and innovate. And cost discipline means fully leveraging operational efficiencies and existing surpluses before turning to higher fees.
These principles are not about weakening oversight. They are about strengthening confidence in regulators, in the system, and in Canada as a place to invest.
- Fragmentation creates inefficiency we can no longer ignore
Fees are only one side of the equation; how we regulate matters just as much.
Canada’s “passport system” proves that cooperation works. In most provinces, firms can deal primarily with a single regulator, with decisions recognized across participating jurisdictions.
Ontario’s absence from that system, however, continues to impose unnecessary duplication, effectively, forcing firms operating nationally to navigate two regulatory systems instead of one.
Ontario joining the passport system would reduce this potential friction, shorten timelines, and lower costs for both firms and regulators without lowering standards or requiring structural change. It would also directly support the government’s stated priorities: to reduce provincial trade barriers, increase productivity, and improve competitiveness in services.
We have been clear in our message to the Ontario government that joining the passport system is the right next step. But it shouldn’t be the last one.
- Building on the existing passport system
As markets evolve, so should our regulatory approach. A more integrated national regulatory system doesn’t require a national regulator. It does require consistency and better coordination, with a simple goal of driving market efficiency.
That means asking what comes next for passporting. Where can we further streamline, and how do we ensure participant firms and investors benefit from a system designed to work as an integrated whole?
These are not theoretical questions. They directly affect whether Canada grows further to be an attractive place for new market entrants, launch new products, deploy capital, and serve investors in an increasingly global market.
- SIMA’s role: connecting the dots
ASC, and others, and we will shortly be meeting with the OSC and BCSC to advance this conversation.
Our objective is simple: a national lens on shared challenges through proactive dialogue and action.
Reduce duplication. Improve transparency. Create predictability. Not abstract policy goals, but practical reforms that enhance outcomes for investors and strengthen Canada’s investment ecosystem in the long term.
Progress will not happen overnight, but it will not happen at all unless we are willing to tackle these issues and move beyond the status quo with pace and urgency.
How we’re advancing the agenda
Regulatory fees
- Conducted cross-jurisdictional fee analysis
- Framed national fee perspective
- Met with AMF and ASC leadership
- Filed AMF fee submission
- Upcoming OSC and BCSC meetings
Reducing regulatory friction
- Advocated Ontario passporting
- Engaged Ontario Finance Ministry
- Ongoing discussions with OSC
The surge in finfluencers
Canadians are changing the way they receive investing information by relying on multiple sources, including online financial content.
SIMA’s new research shows that financial influencers, or “finfluencers,” now play a significant role in shaping investor confidence, behaviour, and expectations, especially among younger and self-directed investors.
In case you missed it, read our research paper and listen to our latest podcast—Insights to Impact—featuring SIMA’s director of research Angélique Bernabé and Benjamin Felix, Chief Investment Advisor with PWL Capital and a highly regarded content creator. And read Angélique’s column in Investment Executive.
Learn:
- what’s driving the surge in finfluencer use
- where the risks and misconceptions lie
- how responsible creators can work alongside advisors and regulators to strengthen investor outcomes.
The surge in finfluencers
Canadians are changing the way they receive investing information by relying on multiple sources, including online financial content.
SIMA's new research shows that financial influencers, or “finfluencers,” now play a significant role in shaping investor confidence, behaviour, and expectations, especially among younger and self-directed investors.
In case you missed it, read our research paper and listen to our latest podcast—Insights to Impact—featuring SIMA’s director of research Angélique Bernabé and Benjamin Felix, Chief Investment Advisor with PWL Capital and a highly regarded content creator. And read Angélique’s column in Investment Executive.
Learn:
- what’s driving the surge in finfluencer use
- where the risks and misconceptions lie
- how responsible creators can work alongside advisors and regulators to strengthen investor outcomes.
Research team
Ian Bragg
Vice-President
Research and Statistics
Angélique Bernabé
Director Research
Abel Olivares
Analyst Research and Statistics
Research team
Ian Bragg
Vice-President, Research and Statistics
Angélique Bernabé
Director, Research
Abel Olivares
Analyst, Research and Statistics
Strengthening Canadian markets in a global environment
By Todd Evans, Vice-President, Capital Markets
Canada’s capital markets do not operate in isolation. What happens beyond our borders increasingly shapes how capital is raised, priced, and deployed at home—and how competitive our markets remain.
Since January, our team has been advancing a focused advocacy agenda aimed at supporting resilient, efficient Canadian markets. A key priority has been the development of voluntary frameworks for equity and debt syndication. Working closely with members, we’re refining practical, industry led voluntary standards that reflect how markets actually function and support confidence, consistency, and clarity for issuers and investors.
The depth of expertise and input we’ve received reinforces the value of an industry driven approach and positions these frameworks to become a meaningful resource for market participants.
We’ve also expanded our focus on how public sector activity shapes capital markets. Our inaugural capital markets webinar in February on Canadian government debt issuance highlighted how transparency and predictability support liquidity and efficient pricing. The strong turnout confirmed that there is real demand for this kind of practical, market relevant discussion—and we intend to build on this.
At the same time, we’re strengthening our voice on the global stage. Earlier this year, I had the opportunity to represent SIMA and the Canadian capital markets industry at the International Council of Securities Associations (ICSA) Annual General Meeting and Conference in New Delhi, including participating in a panel on debt market liquidity.
Discussions on infrastructure financing, regulatory burden, and product innovation reinforced the same point: no market is dealing with these challenges in a vacuum. Markets around the world are grappling with similar pressures, even if the specific contexts differ.
These exchanges reveal opportunities for Canada to learn, adapt, and lead. I’m thankful for the relationships we’ve fostered with our international counterparts and for our ongoing collaboration as capital markets become more interconnected.
Between geopolitical uncertainty and growing cross border regulatory complexity, Canada has an important role to play. SIMA is committed to ensuring our markets remain competitive, credible, and connected to global best practices.
Strengthening Canadian markets in a global environment
By Todd Evans, Vice-President, Capital Markets
Canada’s capital markets do not operate in isolation. What happens beyond our borders increasingly shapes how capital is raised, priced, and deployed at home—and how competitive our markets remain.
Since January, our team has been advancing a focused advocacy agenda aimed at supporting resilient, efficient Canadian markets. A key priority has been the development of voluntary frameworks for equity and debt syndication. Working closely with members, we’re refining practical, industry led voluntary standards that reflect how markets actually function and support confidence, consistency, and clarity for issuers and investors.
The depth of expertise and input we've received reinforces the value of an industry driven approach and positions these frameworks to become a meaningful resource for market participants.
We’ve also expanded our focus on how public sector activity shapes capital markets. Our inaugural capital markets webinar in February on Canadian government debt issuance highlighted how transparency and predictability support liquidity and efficient pricing. The strong turnout confirmed that there is real demand for this kind of practical, market relevant discussion—and we intend to build on this.
At the same time, we're strengthening our voice on the global stage. Earlier this year, I had the opportunity to represent SIMA and the Canadian capital markets industry at the International Council of Securities Associations (ICSA) Annual General Meeting and Conference in New Delhi, including participating in a panel on debt market liquidity.
Discussions on infrastructure financing, regulatory burden, and product innovation reinforced the same point: no market is dealing with these challenges in a vacuum. Markets around the world are grappling with similar pressures, even if the specific contexts differ.
These exchanges reveal opportunities for Canada to learn, adapt, and lead. I’m thankful for the relationships we’ve fostered with our international counterparts and for our ongoing collaboration as capital markets become more interconnected.
Between geopolitical uncertainty and growing cross border regulatory complexity, Canada has an important role to play. SIMA is committed to ensuring our markets remain competitive, credible, and connected to global best practices.
Update: GST/HST on trailing commissions
By Petra Van Daele, Vice-President, Communications & Public Affairs
Over the past several months, SIMA has been actively engaging with Finance Canada and the Canada Revenue Agency (CRA) on the implementation of GST/HST on mutual fund trailing commissions.
This work has included numerous meetings with Finance and CRA officials. Working with members and key service providers, we developed a detailed implementation timeline that reflects the complexity of the industry’s systems and processes. That analysis has also been leveraged by other industry associations in their discussions with government.
A consistent focus throughout this work has been ensuring policymakers understand how the investment industry operates and the interdependencies involved in a change of this size and scope. This includes sequential system dependencies and reliance on shared infrastructure, both of which are central to assessing what a feasible timeline looks like.
As of May 13, SIMA understands that the CRA intends to grant a material extension to the implementation timeline, with a formal, more detailed notice expected to be published by the end of the month.
ry.
Update: GST/HST on trailing commissions
By Petra Van Daele, Vice-President, Communications & Public Affairs
Over the past several months, SIMA has been actively engaging with Finance Canada and the Canada Revenue Agency (CRA) on the implementation of GST/HST on mutual fund trailing commissions.
This work has included numerous meetings with Finance and CRA officials. Working with members and key service providers, we developed a detailed implementation timeline that reflects the complexity of the industry’s systems and processes. That analysis has also been leveraged by other industry associations in their discussions with government.
A consistent focus throughout this work has been ensuring policymakers understand how the investment industry operates and the interdependencies involved in a change of this size and scope. This includes sequential system dependencies and reliance on shared infrastructure, both of which are central to assessing what a feasible timeline looks like.
As of May 13, SIMA understands that the CRA intends to grant a material extension to the implementation timeline, with a formal, more detailed notice expected to be published by the end of the month.
Our new podcast series
Introducing “Insights to Impact“, our new podcast series featuring conversations between some of the investment industry’s leading experts on emerging issues shaping the financial landscape.
In our first episode, we talk to an accredited financial content creator about the rise of finfluencers, SIMA’s latest research paper, the shifting landscape of financial influence, and how advisors can get onboard.
Featuring:
- Angélique Bernabé, Director, Research, SIMA
- Benjamin Felix, PWL Capital Inc
Our new podcast series
Introducing "Insights to Impact", our new podcast series featuring conversations between some of the investment industry’s leading experts on emerging issues shaping the financial landscape.
In our first episode, we talk to an accredited financial content creator about the rise of finfluencers, SIMA’s latest research paper, the shifting landscape of financial influence, and how advisors can get onboard.
Featuring:
-
-
- Angélique Bernabé, Director, Research, SIMA
- Benjamin Felix, PWL Capital Inc
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SIMA’s liquidity risk-management submission
On March 27, we responded to the CSA’s proposed changes to the regulatory framework for investment fund LRM. While we support strengthening existing liquidity rules, we are urging regulators to minimize regulatory burden and complexity. For example, we asked them to exclude non-reporting issuers and ETFs, omit pre-trade liquidity checks (as this is already covered elsewhere), and give firms flexibility on stress testing and policies tailored to each fund. We also asked for a minimum 12-month rollout and clearer separation of liquidity rules from illiquid-asset limits to ease operations. If some of the changes move forward, especially the pre-trade liquidity assessments, a realistic timeline for implementation would be 18 months.
SIMA’s liquidity risk-management submission
On March 27, we responded to the CSA’s proposed changes to the regulatory framework for investment fund LRM. While we support strengthening existing liquidity rules, we are urging regulators to minimize regulatory burden and complexity. For example, we asked them to exclude non-reporting issuers and ETFs, omit pre-trade liquidity checks (as this is already covered elsewhere), and give firms flexibility on stress testing and policies tailored to each fund. We also asked for a minimum 12-month rollout and clearer separation of liquidity rules from illiquid-asset limits to ease operations. If some of the changes move forward, especially the pre-trade liquidity assessments, a realistic timeline for implementation would be 18 months.
Why LRM matters
LRM continues to be a central issue for investment funds because it helps ensure they can meet redemption requests in an orderly way, even during periods of market stress. When a fund can manage liquidity well, it protects both investors who redeem and those who remain in the fund.
Strong LRM also reduces the risk that stress in one fund could ripple into a wider liquidity crisis through a contagion effect. In that sense, it is not only an operational issue for fund managers, but also a broader market-stability issue.
Ensuring liquidity during redemptions
At its core, LRM is about making sure a fund has the cash or liquid assets it needs when investors want to redeem. If risk-management controls are weak, a fund may be forced to sell assets quickly and at unfavorable prices, disadvantaging investors who still own the fund.
That is why regulators have put increasing emphasis on this topic. Their goal is to support fair treatment of investors, strengthen fund resilience, and help maintain confidence in capital markets. Regulators worldwide are also paying closer attention to how funds manage liquidity, especially under stress.
For firms, the takeaway is straightforward: LRM should be a priority. It is a core part of sound governance, investor protection, and long-term financial stability.
In our first podcast episode of Policy to Practice, we dive into the CSA’s proposed changes to strengthen the liquidity risk-management framework for investment funds and what the industry can expect next.
Why LRM matters
LRM continues to be a central issue for investment funds because it helps ensure they can meet redemption requests in an orderly way, even during periods of market stress. When a fund can manage liquidity well, it protects both investors who redeem and those who remain in the fund.
Strong LRM also reduces the risk that stress in one fund could ripple into a wider liquidity crisis through a contagion effect. In that sense, it is not only an operational issue for fund managers, but also a broader market-stability issue.
Ensuring liquidity during redemptions
At its core, LRM is about making sure a fund has the cash or liquid assets it needs when investors want to redeem. If risk-management controls are weak, a fund may be forced to sell assets quickly and at unfavorable prices, disadvantaging investors who still own the fund.
That is why regulators have put increasing emphasis on this topic. Their goal is to support fair treatment of investors, strengthen fund resilience, and help maintain confidence in capital markets. Regulators worldwide are also paying closer attention to how funds manage liquidity, especially under stress.
For firms, the takeaway is straightforward: LRM should be a priority. It is a core part of sound governance, investor protection, and long-term financial stability.
In our first podcast episode of Policy to Practice, we dive into the CSA’s proposed changes to strengthen the liquidity risk-management framework for investment funds and what the industry can expect next.
Our team is growing! We recently welcomed three new policy team members who bring extensive experience in asset management, regulatory compliance, investment taxation, and regulatory affairs. Their combined knowledge supports our growing advocacy efforts and strengthens our capacity to meet the evolving needs of our members. Get to know Marcy, Rose, and Samantha!
Meet Marcy Einarsson
Director, Regulatory Compliance
What motivated you to join SIMA?
I wanted a role where I would use a lot of my experience in compliance but would also be able to try something different. I like that I will be able to stay on top of things because SIMA is involved in absolutely everything going on in the industry.
Describe your role
I will be bringing more of a compliance lens as well as insights into the pressures members are facing and how we can support them. I am also contributing to priorities like submissions.
What’s one issue or opportunity in the investment industry that you’re most excited to work on?
I think there’s an opportunity for me to put my hand up and to help younger women in their careers.
What are you passionate about outside of work?
I met an awesome group of women at the gym who take strength training way more seriously than I do, but they are inspiring me to work harder. I also learned to row since I moved to Niagara-on-the-Lake.
Meet Rose Park
Director, Asset Managers
What motivated you to join SIMA?
This is a particularly exciting and dynamic time to be at SIMA given the pace of regulatory and technological change within the industry.
Describe your role
I am responsible for analysis and interpretation of regulatory issues and policy matters affecting asset managers and distributors. I’ll also be involved in building consensus among industry participants and advocating on their behalf.
What’s one issue or opportunity in the investment industry that you’re most excited to work on?
AI and technology risk management, the developing regulatory framework governing tokenized assets in Canada, and SIMA’s continuing advocacy efforts on private retirement savings reform.
What are you passionate about outside of work?
Reading, getting out, being active, karaoke, trying new restaurants, and travelling with my husband and children.
Meet Samantha Jennings
Senior Policy Adviser, Tax
What motivated you to join SIMA?
In my prior role as a tax litigator at the DOJ, we would advance law through the court system which could take a long time. At SIMA, you get to be proactive in addressing issues as they come out.
Describe your role
I am leading tax research, focusing on emerging tax issues and trends, and formulating responses.
What’s one issue or opportunity in the investment industry that you’re most excited to work on?
I’m very excited about responding to legislation as it’s happening. SIMA is taking a more proactive approach, and it’s great that there is open dialogue with the CRA and the Ministry of Finance.
What are you passionate about outside of work?
I’m part of a curling team. I play pickleball. I’m in a book club. I like spending time outdoors and working out in the mornings.
Take a peek at our upcoming events!
June 2 – SIMA/Fundserv Golf Classic
The annual golf classic takes place at Lionhead Golf Club in Mississauga on Tuesday, June 2.
Join us for a day of friendly competition and networking! All proceeds from the event go to JA Canada.
June 18 – Senior fraud webinar
Join our upcoming webinar exploring the risks of financial exploitation facing seniors today.
The session will examine:
- the latest fraud trends and their staggering financial impact
- what’s working in prevention, and how policies, procedures, and global practices must evolve
- how individuals and organizations can adapt in an AI-enabled world
Featuring:
- Marcy Einarsson, Director, Regulatory Compliance, SIMA (moderator)
- Laura Tamblyn Watts, CEO, CanAge
- Hilary McMeekin Director, Communications & Investor Education, ASC
October 29 – 2026 SIMA Annual Leadership Conference
Save the date for our next annual conference! Mark your calendars for Thursday, October 29 at the Fairmont Royal York Hotel in Toronto for a day of learning, inspiration, and connecting with industry professionals.
Details and registration to come.
If you missed it:
SIMA/CSA FinHub webinar
In case you missed it, catch up on the webinar we hosted with the CSA Financial Innovation Hub (FinHub) in April . Watch the recording and learn about key regulatory initiatives driving innovation in Canadian capital markets:
- FinHub’s data-portability report
- the CSA’s tokenization project
- emerging regulatory approaches to AI
Thank you to everyone who joined the session and to our speakers:
- Daniela Follegot, Vice-President, Asset Managers, SIMA (moderator)
- Dr. Ryan Clements, Director, Advanced Research and Knowledge Management, ASC, and Chair of the CSA FinHub
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