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Policy

Policy

As the voice of Canada’s investment funds industry, SIMA’s principal role is to advocate on behalf of its members and their investors. We review and analyze public policy issues, including federal and provincial legislation and regulatory and self-regulatory initiatives and develop and communicate approaches that advance our mission – to foster a strong, stable investment sector where investors can realize their financial goals.

SIMA files many submissions to policy makers and other stakeholders. We also commission reports from independent third-party think tanks and analysts on topical issues, source and share independently- produced research from around the world and provide public commentary. Our Policy and Advocacy pages provide access to all of the documents we have available on a subject by subject basis.

Featured Documents

Submission - Finance - Definition of “Investment Fund” in Subsection 251.2(1) of the Income Tax Act (Canada) (December 10, 2025)
(December 10, 2025)

Submission - CIRO - Proposed Guidance on Order Execution Only Account Services and Activities (November 17, 2025)
(November 17, 2025)

Submission – CIRO - Proposed Amendment of Approved Person Fees Component within the Annual Fee of Dealer Member Fee Model (November 7, 2025)
(November 7, 2025)

Submission - CDS Clearing and Depository Services Inc - Proposed Significant Changes to Discontinue the Fee Rebate Model and Reduce Certain Core Clearing and Settlement Fees & Proposed Amendments to Eliminate Network Connectivity Fees and to Eliminate Report File Transmission Fees (November 3, 2025)
(November 3, 2025)

Submission - CSA - Consultation Paper 81-409 Enhancing Exchange-Traded Fund Regulation - Proposed Approaches and Discussion (October 31, 2025)
(October 31, 2025)

Submission - CIRO - CIRO White Paper and Proposed Rule Amendments to Modernize Account Transfers (October 8, 2025)
(October 8, 2025)

Submission – CSA – Notice and Request for Comment 25-314 – Proposed Approach to Oversight and Refinements to the Proposed Binding Authority Framework for an Identified Ombudservice (OBSI) (September 29, 2025)
(September 29, 2025)

Submission - Philippe Lebel - AMF - Recalibration of AMF Fees (September 19, 2025)
(September 19, 2025)

Submission - OSC - Proposed Amendments to OSC Rule 48-501 Trading During Distributions, Formal Bids and Share Exchange Transactions and Proposed Changes to Companion Policy 48-501 Trading During Distributions, Formal Bids and Share Exchange Transactions (September 17, 2025)
(September 17, 2025)

Submission to Finance - Implementation of CARF & Amendments to CRS (September 12, 2025)
(September 12, 2025)

SIMA urges reform of Canada’s retirement-savings framework
(August 27, 2025)

Canada’s Retirement Puzzle: Why Private Savings Must be at the Centre of Reform – Summary
(August 26, 2025)

Submission - CIRO - CIRO Rule Consolidation Project - Phase 5 (June 24, 2025)
(June 24, 2025)

Submission - Mr. Félix Fortin-Lauzier - Quebec Government - Bill 92 (May 16, 2025)

Comments on transfer of mutual advisors oversight from CSF to CIRO.

(May 16, 2025)

Submission - OSC - Me Philippe Lebel - CSA Consultation - Principal Distributor Model (April 28, 2025)
(April 28, 2025)

Submission - CIRO - Proposal to Harmonize CIRO Continuing Education (CE) Programs (March 18, 2025)
(March 18, 2025)

Submission – Competition Bureau – Consultation – Environmental claims and the Competition Act – Draft Guidance (March 7, 2025)
(March 7, 2025)

Submission - CIRO - Non-Tailored Advice in the Order Execution Only Channel (February 28, 2025)
(February 28, 2025)

Submission - OSC Consultation 81-737- Improve Retail Investor Access to LTA through Investment Fund Product Structures (February 21, 2025)
(February 21, 2025)

Submission - CSA Consultation – Amendments to Multilateral Instrument 13-102 System Fees (February 19, 2025)
(February 19, 2025)