Submissions & Letters

Submissions & Letters

As the national association representing the investment industry’s position on securities regulation, public policy and industry issues on behalf of our 118 IIROC-regulated investment dealer Member firms, the IIAC regularly develops submissions for consideration by provincial regulators, IIROC and federal and provincial governments.

IIAC comments on National Instrument 81-105 Mutual Fund Sales Practices and Related Consequential Amendments [PDF]
December 13, 2018

Joint Letter to Federal Finance Minister Bill Morneau Advocating a Publicly Accessible Pan-Canadian Beneficial Ownership Registry [PDF]
December 10, 2018

IIAC submits letter to OSC re: Market Data Fees [PDF]
December 10, 2018

IIAC Requests Relief from Unintended Consequences of Repeal of Section 958(b)(4) of the U.S. Internal Revenue Code [PDF]
November 28, 2018

IIAC Submits Second Round of Comments re: Amendments to the Rules of Bourse de Montreal inc. to clarify the governance structure of the Regulatory Division. [PDF]
November 23, 2018

IIAC Response to IIROC Notice 18-0153 – Proposed Amendments to Dealer Member Rules and Form 1 regarding the securities concentration test and designated rating organizations [PDF]
November 8, 2018

IIAC Response to CSA’s Proposed Client Focused Reforms [PDF]
October 19, 2018

IIAC response to request for comment on CDIC proposed amendments to Joint and Trust Account Disclosure By-law [PDF]
September 28, 2018

IIAC Response to request for comment on IIROC Proposed Provisions Respecting Client Identifiers [PDF]
September 26, 2018

IIAC Comments on Proposed Finance Canada Regulations re: Proceeds of Crime (Money Laundering) and Terrorist Financing [PDF]
September 7, 2018

IIAC Comments on CSA Proposal for Mandatory Post-Trade Transparency of Trades in Government Debt Securities [PDF]
August 24, 2018

AFME, IIF & IIAC Joint Response to the FATF Draft Risk-Based Approach Guidance for the Securities Sector (AML/CFT) [PDF]
August 23, 2018

IIAC Comments on Draft Prospectus and Related Registration Exemptions for the Cooperative Capital Markets Regulatory System [PDF]
August 7, 2018

Submission to the House of Commons Standing Committee on Finance: Pre-Budget Consultations in Advance of the 2019 Budget [PDF]
August 3, 2018

Submission to the Independent Tax Review Committee, Newfoundland and Labrador [PDF]
July 30, 2018

IIAC Responds to MFDA Discussion Paper on Expanding Cost Reporting [PDF]
July 20, 2018

IIAC Submission re: Proposed Amendments to CDS Fee Schedule for New York Link/DTC Direct Link Services [PDF]
July 13, 2018

IIAC Response to Amendments to Article 4002 of the Rules of Bourse de Montreal Inc. Regarding Non-Compliance Reporting [PDF]
June 21, 2018

IIAC Comments to IRS on Notice 2018-43, Priority Guidance for 2018-2019 [PDF]
June 15, 2018

IIAC Response re: CSA Staff Notice 61-303 and Request for Comment – Soliciting Dealer Arrangements [PDF]
June 11, 2018

IIAC Response to IIROC Debt Securities Transaction Reporting Requirements [PDF]
June 6, 2018

IIAC provides comments on OBSI’s Terms of Reference Renewal Project [PDF]
May 31, 2018

IIAC Response re IIROC’s Enforcement Alternative Forms of Disciplinary Action Proposal [PDF]
May 23, 2018

IIAC Comments on IIROCs Proposed Amendments Respecting Mandatory Reporting of Cybersecurity Incidents [PDF]
May 22, 2018

IIAC Submission on Department of Finance AML and ATF Regime Discussion Paper [PDF]
May 18, 2018

Testimony before the House of Commons Standing Committee on Finance on Bill C-74, the Budget Implementation Act, 2018 [PDF]
May 1, 2018

IIAC Response to Ontario Government Regulation of Financial Planners Consultation Paper [PDF]
April 16, 2018

IIAC Letter to the U.S. Treasury and IRS re: Section 871(m) Regulations [PDF]
April 16, 2018

IIAC Comments on BCSC’s Consultation Paper, Securities Law Framework for FinTech Regulation [PDF]
April 3, 2018

IIAC Whitepaper – Filling the Gap: Perspectives on Transparency for Canada’s Government Debt [PDF]
March 29, 2018

Testimony before the House of Commons Standing Committee on Finance on the Statutory Review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act [PDF]
March 27, 2018

Letter to Quebec Minister of Immigration re: Request for Information – Immigrant Investor Program (in French) [PDF]
March 26, 2018

IIAC Submission to IIROC re Proficiency Requirements for Research Supervision [PDF]
March 16, 2018

IIAC Letter to IRS re Responsible Officer Certification Requirements [PDF]
March 16, 2018

IIAC Submission to IIROC on Proposed Dealer Member Plain Language Rule Book – Proposed Amendments [PDF]
March 5, 2018

IIAC Submission to IIROC on Continuing Education Rules – Proposed Amendments [PDF]
February 26, 2018

IIAC Supports Amendments to IIROC Minimum Dealer Regulation Fee [PDF]
February 2, 2018

IIAC Shares Concerns About the Montreal Exchange’s Extended Hours Initiative [PDF]
January 30, 2018

IIAC Response to the Draft OECD Mandatory Disclosure Rules for Addressing CRS Avoidance Arrangements and Offshore Structures [PDF]
January 15, 2018

IIAC Letter to IRS and US Treasury Calling for an Extension of Notice 2010-46 and the Qualified Securities Lender Regime [PDF]
November 30, 2017

IIAC Submission to IIROC on Proposed Provisions Respecting Client Identifiers [PDF]
November 10, 2017

Presentation to the Standing Senate Committee on National Finance: Proposed Changes to the Income Tax Act respecting the Taxation of Private Corporations [PDF]
October 24, 2017

IIAC Letter to the Montreal Exchange Calling for and Extension of the LOPR Certification Deadline [PDF]
October 24, 2017

IIAC Request for Extension for Treaty Statement Expiry Date for Existing Clients [PDF]
October 12, 2017

Presentation to the House of Commons Standing Committee on Finance: Pre-Budget Consultations in Advance of the 2018 Budget [PDF]
October 16, 2017

IIAC Responds to CSA Request for Comment on NI 45-102 Resale of Securities – Foreign Issuer Exemption [PDF]
September 27, 2017

IIAC Letter to Treasury and IRS re Executive Order 13777 (Enforcing the Regulatory Reform Agenda) and Section 871(m) [PDF]
September 22, 2017

IIAC Letter to the CSA Regarding National Instrument 93-101 Derivatives: Business Conduct [PDF]
September 1, 2017

IIAC Letter to IIROC re: Rule Amendments Relating to the Futures Market Segregation and Portability Customer-Protection Regime [PDF]
August 15, 2017

IIAC Response to CSA Consultation Paper 51-404 – Considerations for Reducing Regulatory Burden for Non-Investment Fund Reporting Issuers [PDF]
July 28, 2017

Submission to the House of Commons Standing Committee on Finance: Pre-Budget Consultations in Advance of the 2018 Budget [PDF]
August 4, 2017

IIAC Letter to the Montreal Exchange Regarding its Basis Trades on Close Proposal [PDF]
July 21, 2017

Quebec Immigrant Investor Program – Request for deferral of regulatory requirements [PDF]
July 7, 2017

IIAC Comments on IIROC’s Continuing Education Proposals [PDF]
June 30, 2017

IIAC Submits Response to IIROC’s Re-Published Proposed Amendments Regarding Reporting of Certain Trades to Acceptable Foreign Trade Reporting Facilities [PDF]
June 26, 2017

IIAC Letter to the Montreal Exchange re Proposal to Introduce Auctions During the Trading Process [PDF]
June 14, 2017

IIAC Letter to the Montreal Exchange on Amendments to Options Strategies Execution Procedures [PDF]
June 13, 2017

IIAC Response to CSA Consultation Paper 81-408 Consultation on the Option of Discontinuing Embedded Commissions [PDF]
June 9, 2017

IIAC Letter to the Montreal Exchange on the Governance Structure of its Regulatory Division [PDF]
June 1, 2017

IIAC letter to the CSA on allowing IIROC-regulated firms to offer legal binary options trading [PDF]
May 25, 2017

IIAC Letter to the IRS on Changes to U.S. Tax Reporting and Withholding Requirements [PDF]
May 24, 2017

IIAC Responds to OSC 2017-18 Statement of Priorities [PDF]
May 9, 2017

IIAC Responds to IIROC’s Plain-language Rulebook Proposals [PDF]
May 8, 2017

IIAC Letter to the Montreal Exchange Calling for a LOPR Alert System [PDF]
April 20, 2017

IIAC Letter to the Montreal Exchange Regarding Position Limit Increases for Options on Equity-Holding ETFs [PDF]
April 18, 2017

IIAC Letter to Montreal Exchange Calling for Clarity on Manipulative or Deceptive Methods of Trading Rules [PDF]
April 12, 2017

IIAC Letter to Department of Finance on Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime [PDF]
April 7, 2017

IIAC Letter to IRS Calling for an Extension of the QI/QDD Renewal and Application Deadline [PDF]
March 6, 2017

IIAC Comment Letter to the AMF Calling for an End to Illegal Binary Options Trading [PDF]
February 24, 2017

IIAC Response to IIROC’s Order Execution Only Guidance [PDF]
February 3, 2017

IIAC Seeks Extension of Deadline to Remit Payment of Withholding Taxes to Revenu Québec (in French only) [PDF]
January 31, 2017

IIAC Response to New IIROC Debt Information Processor Fee Model and Proposed Expanded Debt IP Service [PDF]
January 13, 2017

IIAC Letter to IRS Proposing Simplified U.S. Tax Withholding Procedures for Section 302 Distributions [PDF]
December 23, 2016

IIAC Letter to Montreal Exchange on the Introduction of a Process to Impose Fines for Minor Violations [PDF]
December 22, 2016

IIAC Letter to the IRS and US Treasury on Concerns re Changes to Section 871m and QDD Announced in Notice 2016-76 [PDF]
December 12, 2016

IIAC Letter to Ontario Ministry of Government and Consumer Services re Business Law Advisory Council Report [PDF]
December 12, 2016

IIAC Response to IIROC Proposed Provisions Regarding Best Execution [PDF]
December 12, 2016

IIAC Comments on Proposed Amendments to NI 24-101 and CSA Consultation Paper 24-402 [PDF]
November 11, 2016

IIAC Letter to Montreal Exchange on Phase 2 of Rule Modernization Project [PDF]
October 18, 2016

IIAC Letter to OSC re Level Playing Field for IPO Financial Statement Requirements [PDF]
October 7, 2016

IIAC Comments on Proposed CRM2 Amendments to NI 31-103 and its Policy [PDF]
October 5, 2016

IIAC Submission to CSA on Consultation Paper 33-404 – Proposals to Enhance the Obligations of Advisers, Dealers, and Representatives Toward Their Clients [PDF]
September 30, 2016

IIAC Response to Proposed OSC Rule 72-503 – Distributions Outside of Canada [PDF]
September 28, 2016

IIAC Letter to ASC on OTC Trading in CFDs, Foreign Exchange Contracts and Binary Options [PDF]
September 9, 2016

IIAC Letter to IRS re supplementary comments on the Proposed QI Agreement [PDF]
August 31, 2016

IIAC Letter to Montreal Exchange on Phase 2 of Rule Modernization Project [PDF]
August 31, 2016

IIAC Generally Supports IIROC’s Amendments to Schedule 12 of Form 1 Re: Margin on Futures Contracts [PDF]
August 22, 2016

IIAC Comments on Montreal Exchange Proposal to Introduce Share Futures Contracts [PDF]
August 11, 2016

IIAC Pre-Budget Submission to House of Commons Standing Committee on Finance (2016-17) [PDF]
August 3, 2016

IIAC Comments on CSA Consultation Regarding Proposed Proxy Voting Protocols [PDF]
July 15, 2016

IIAC Comments on IIROC’s Re-Publication of the Proposed Plain Language Rule (PLR) Book [PDF]
July 8, 2016

IIAC Response to the CSA re Order Protection Rule Trading Fee Cap Proposal [PDF]
July 6, 2016

IIAC Responds to Revised Capital Markets Stability Act [PDF]
July 6, 2016

IIAC Comment Letter to Montreal Exchange re Reform of Market Making Programs [PDF]
June 27, 2016

IIAC Response to IIROC re Proposed Amendments to UMIR 6.4 – Acceptable Foreign Trade Reporting Facilities [PDF]
June 20, 2016

IIAC Responds to Expert Committee’s Recommendations on Financial Planning [PDF]
June 10, 2016

IIAC Provides Further Comment to Treasury and IRS on Section 871(m) Regulations [PDF]
June 2, 2016

Letter from Industry Coalition to Federal, Provincial and Territorial Finance Ministers Seeking National Approach to Retirement Savings Reform [PDF]
June 1, 2016

IIAC Comment Letter to the Montreal Exchange re: Phase 1 of its Rule Modernization Project [PDF]
May 20, 2016

IIAC Letter to IRS re LOB [PDF]
April 19, 2016

IIAC Comment Letter on OSC Statement of Priorities 2016-2017 [PDF]
April 12, 2016

IIAC Response to IIROC’s Best Execution Proposal [PDF]
March 24, 2016

IIAC Comments on MFDA Consultation on Expanded Cost Reporting for Investment Funds [PDF]
March 10, 2016

IIAC Comments on CSA’s Fund Risk Classification Methodology [PDF]
March 9, 2016

IIAC Response to IIROC White Paper – The Public Policy Implications of Changes to Rules Regarding Proficiency Upgrade Requirements and Directed Commissions on the IIROC Platform [PDF]
March 7, 2016

IIAC 2016 Pre-Budget Submission to House of Commons Standing Committee on Finance [PDF]
February 19, 2016

IIAC Letter to Montreal Exchange Seeks Amendment to Special Terms Transaction Reporting [PDF]
February 10, 2016

IIAC Comment Letter on Revised Capital Markets Act and Draft Regulations for CCMRS [PDF]
December 21, 2015

IIAC Provides Further Comment to IRS on Section 871(m) Regulations [PDF]
December 17, 2015

IIAC Response to ASC-Nunavut Start-Up Prospectus Exemption [PDF]
December 9, 2015

IIAC Comments on Bourse de Montréal Inc.’s Proposed Amendments as Issued in Circular 134-15 [PDF]
December 9, 2015

IIAC Comments on Re-Publication of Proposed Amendments of Requirement to Disclose Membership in IIROC as a Dealer Member [PDF]
December 7, 2015

IIAC Comments on IIROC’s Proposed Guidance on Time Synchronization [PDF]
November 18, 2015

IIAC Comments to the ASC re Albert Investment Dealer Prospectus Exemption [PDF]
November 9, 2015

IIAC Pre-Workshop Comments to the OSC re Implementing a Segregation and Portability Regime for CCPs Serving Domestic Futures Markets [PDF]
November 4, 2015

IIAC Responds to CSA’s Proposed Debt Market Transparency Framework [PDF]
October 30, 2015

IIAC Comment Letter to Bourse de Montreal Concerning Circular 115-15, 116-15, 117-15 and 118-15 [PDF]
October 23, 2015

IIAC Submission to the CSA re Proposed Amendments to NI 45-106 Prospectus Exemptions – Relating to Reports of Exempt Distribution [PDF]
October 13, 2015

IIAC Responds to Ontario Ministry of Finance Consultations on Financial Advisory and Financial Planning Policy Alternatives [PDF]
September 21, 2015

IIAC Response to the Ontario Changing Workplaces Review [PDF]
September 16, 2015

IIAC Comment Letter to Finance re Financial Institutions Act and Credit Union Incorporation Act Review [PDF]
September 16, 2015

IIAC Comment Letter to the CSA re ETF Facts [PDF]
September 16, 2015

IIAC Comment Letter to IIROC on Short-marking Exempt Order Definition [PDF]
September 11, 2015

IIAC Submission on a Voluntary Supplement to the Canada Pension Plan [PDF]
August 28, 2015

IIAC Comment Letter to Finance on AML Regulations [PDF]
August 25, 2015

IIAC Comments to CSA re the Application of the Order Protection Rule to Marketplaces Imposing Systematic Order Processing Delays (Speedbumps) [PDF]
August 17, 2015

IIAC Pre-Budget Submission to House of Commons Standing Committee on Finance (2015-16) [PDF]
July 23, 2015

IIAC Response to IIROC’s Proposed Amendments to Unprotected Markets and Order Protection Rules [PDF]
July 13, 2015

IIAC Note to Member firms re: IIROC’s Strategic Consultations [PDF]
July 9, 2015

IIAC Submission to CSA on Proposed Take-Over Bid Amendments [PDF]
June 16, 2015

IIAC Submission to IIROC re: Proposed Guidance on Marketplace Thresholds 2015 [PDF]
May 29, 2015

IIAC Comments to IIROC on Research Analyst Rules [PDF]
April 24, 2015

IIAC 2015 Federal Budget Summary [PDF]
April 21, 2015

IIAC Response to CSA Consultation Paper 92-401 Derivatives Trading Facilities [PDF]
March 30, 2015

IIAC Letter to Finance Requesting De Minimis Financial Institution Definition CPI Adjustment [PDF]
March 20, 2015

IIAC Letter to IRS and US Treasury Requesting Delay in Application of Final Section 871(m) Regulations [PDF]
March 2, 2015

IIAC Letter to Finance on Carrying on a Business and TFSAs [PDF]
February 27, 2015

IIAC Letter to CRA on Inadvertent Overdrafts [PDF]
February 27, 2015

IIAC Response to CSA re Proposed Rights Offering Regime [PDF]
February 24, 2015

IIAC Letter to CRA re Three Actions to Address TFSA Concerns [PDF]
February 18, 2015

IIAC Response to ORPP Consultation Paper [PDF]
February 13, 2015

IIAC Comments on IIROC’s Proposed Fee Model for its planned Debt Securities Transaction Reporting Rule [PDF]
February 9, 2015

IIAC – Why Cooperative Regulator Is Better [PDF]
February 9, 2015

IIAC Letter to Finance Regarding TFSA Concerns [PDF]
December 23, 2014

IIAC Response to CSA Chair and Members on CRM2 Calendar-Year Harmonization [PDF]
December 20, 2014

IIAC Letter to Revenu Québec Regarding Tax-Reporting Changes [PDF]
December 19, 2014

IIAC Response re Alberta Unclaimed Personal Property and Vested Property Act [PDF]
December 15, 2014

IIAC Response to CDS consultation on Issuer fees [PDF]
December 12, 2014

IIAC Letter to CRA Seeking Plain-Language Communications Pieces on Carrying on Business in TFSAs, Keeping Tax Slips and Ensuring Same Surnames [PDF]
December 8, 2014

IIAC Comment Letter on the Cooperative Capital Markets Regulatory System [PDF]
December 8, 2014

365 Day Tax Reporting Cycle
[PDF]
November 28, 2014

IIAC Letter to IIROC on Book Cost Definition [PDF]
November 17, 2014

IIAC Letter to IIROC re Revised CRM2 Proposed Rules for 2015-16 [PDF]
November 17, 2014

IIAC Response to IIROC re Proficiency Assurance Model: Consultation Relating to Expiry of CSI Contract [PDF]
November 17, 2014

IIAC Response to Montreal Exchange re Derivative Position Limits [PDF]
November 3, 2014

IIAC Comments to CSA re Order Protection Rule 2014 [PDF]
September 19, 2014

IIAC-CPA Letter to Finance Re T1135 Changes [PDF]
September 15, 2014

IIAC Letter and Email to Alberta Treasury Board and Finance on Changes to Unclaimed Property Legislation [PDF]
August 22, 2014

IIAC Response to ASC re Proposed Consequential Rule Amendments Relating to Derivatives Regulation and the Securities Amendment Act 2014 [PDF]
August 21, 2014

Ontario Government Issues RFP for Investment Dealer Services
Refer to blog posting dated August 20, 2014

Exemption from the Provisions of Rules 91-507 Trade Repositories and Derivatives Data Reporting for IIROC Registered Dealers [PDF]
August 13, 2014

IIAC Request to IIROC for Extension – Order Execution Services – Client Contracts [PDF]
August 6, 2014

IIAC 2014 Pre-Budget Submission – House of Commons Standing Committee [PDF]
August 6, 2014

IIAC Letter to CSA on NI 21-101 – Marketplace Operation [PDF]
July 25, 2014

IIAC Response to IIROC re Lower Minimum Capital Requirements [PDF]
July 9, 2014

IIAC Response to IIROC re Proposed Guidance on Marketplace Thresholds [PDF]
July 3, 2014

IIAC Letter to Finance and CRA re “Carrying on a Business” and Borrowing Within TFSAs [PDF]
July 3, 2014

IIAC Response to IIROC re Provisions and Guidance Respecting Order Execution Services [PDF]
June 23, 2014

IIAC Response to OSC re: Prospectus Amendments [PDF]
June 18, 2014

IIAC Response re: Multilateral Instrument Crowdfunding[PDF]
June 18, 2014

IIAC Response re: Multilateral Instrument OM Exemption [PDF]
June 18, 2014

IIAC Response to IIROC Fee Model Guideline Amendments [PDF]
June 10, 2014

IIAC Responds to IIROC Proposed Guidance on Underwriting Due Diligence [PDF]
June 4, 2014

IIAC Supports IIROC Guidance Clarifying Part Time CFOs [PDF]
June 2, 2014

IIAC Comments on IIROC Personal Financial Dealings Rule [PDF]
May 28, 2014

IIAC Responds to CSA re: Proposed Changes to Accredited Investor and Minimum Amount Exemptions [PDF]
May 28, 2014

CBRF Response to IOSCO Questionnaire [PDF]
May 28, 2014

IIAC Response to OSC Statement of Priorities 2014-2015 [PDF]
May 27, 2014

IIAC Response to Implementation of Stage 3 of Point of Sale Disclosure [PDF]
May 26, 2014

IIAC Pre-budget Letter to Quebec’s Minister of Finance Re Recommendations to Revive Quebec’s IPO Market (available only in French) [PDF]
May 16, 2014

IIAC Response to Proposed Amendments to NI 45-106 – Short Term Debt Prospectus Exemptions [PDF]
April 23, 2014

IIROC Response to IIAC Letter on Wash Trades [PDF]
April 21, 2014

IIAC Submission to IIROC re Wash Trades March 14 – posted April 21 [PDF]
April 21, 2014

IIAC-IIROC and CSA Response on CRM2 2015 and 2016 Disclosure Requirements [PDF]
April 10, 2014

IIAC Letter to Alberta Treasury Board and Finance on PRPPs and RRSPs [PDF]
April 4, 2014

IIAC Letter to Alberta Government Re Retirement Plan Hardship Unlocking and PRPP [PDF]
April 4, 2014

IIAC Letter to BC Deputy Attorney General Re: Irrevocable Beneficiary Provisions [PDF]
March 26, 2014

IIAC Response to OSC Rule 24-503 Clearing Agency Requirements [PDF]
March 19, 2014

Canada’s Investment Industry: Protecting Senior Investors – Compliance, Supervisory and Other Practices When Serving Senior Investors [PDF]
March 18, 2014

IIAC Letter to CRA on Proposed T1135 Changes for 2014 [PDF]
March 14, 2014

IIAC Letter to IRS re REG-120282-10 (Dividend Equivalents) Supplemental Comments [PDF]
March 12, 2014

IIAC Letter to CSA on Notice 81-324 – Mutual Fund Risk Classification [PDF]
March 12, 2014

IIAC Response to IIROC’s Proposed Debt Securities Transaction Reporting Rule [PDF]
March 10, 2014

IIAC Submission to IIROC re Single Stock Circuit Breakers 2014 [PDF]
March 10, 2014

IIAC Response to CSA re Proposed Amendments to NI 31-103 [PDF]
March 4, 2014

IIAC E-Mail to Revenu Quebec re Relevé 18 (RL-18) [PDF]
February 23, 2014

IIAC Letter to IRS re Notice 2014-14 Providing Timing Relief for Application of 871(m) Regulations to ELIs [PDF]
February 20, 2014

IIAC Response to Republication of Proposed Consolidation of IIROC Enforcement, Procedural, Examination and Approval Rules [PDF]
February 11, 2014

IIAC Letter to IIROC and CSA on CRM2 July 15 2014 Disclosure Requirements [PDF]
February 10, 2014

IIAC Response re: Notice 13-0269 Revised Sanction Guidelines [PDF]
February 3, 2014

IIAC Response to Finance re: Financial Planning Consultation [PDF]
January 31, 2014

IIAC Response to Ontario Finance on Ontario PRPPs [PDF]
January 20, 2014

IIAC Response to CSA re Proposed Existing Security Holder Exemption [PDF]
January 20, 2014

IIAC Submission to IIROC re: Proposed Provisions Respecting Order Execution Services as a Form of Third Party Electronic Access to Marketplaces [PDF]
January 10, 2014

IIAC Letter to Finance Regarding TFSA Concerns [PDF]
December 23, 2014

IIAC Response to CSA Chair and Members on CRM2 Calendar-Year Harmonization [PDF]
December 20, 2014

IIAC Letter to Revenu Québec Regarding Tax-Reporting Changes [PDF]
December 19, 2014

IIAC Response re Alberta Unclaimed Personal Property and Vested Property Act [PDF]
December 15, 2014

IIAC Response to CDS consultation on Issuer fees [PDF]
December 12, 2014

IIAC Letter to CRA Seeking Plain-Language Communications Pieces on Carrying on Business in TFSAs, Keeping Tax Slips and Ensuring Same Surnames [PDF]
December 8, 2014

IIAC Comment Letter on the Cooperative Capital Markets Regulatory System [PDF]
December 8, 2014

365 Day Tax Reporting Cycle
[PDF]
November 28, 2014

IIAC Letter to IIROC on Book Cost Definition [PDF]
November 17, 2014

IIAC Letter to IIROC re Revised CRM2 Proposed Rules for 2015-16 [PDF]
November 17, 2014

IIAC Response to IIROC re Proficiency Assurance Model: Consultation Relating to Expiry of CSI Contract [PDF]
November 17, 2014

IIAC Response to Montreal Exchange re Derivative Position Limits [PDF]
November 3, 2014

IIAC Comments to CSA re Order Protection Rule 2014 [PDF]
September 19, 2014

IIAC-CPA Letter to Finance Re T1135 Changes [PDF]
September 15, 2014

IIAC Letter and Email to Alberta Treasury Board and Finance on Changes to Unclaimed Property Legislation [PDF]
August 22, 2014

IIAC Response to ASC re Proposed Consequential Rule Amendments Relating to Derivatives Regulation and the Securities Amendment Act 2014 [PDF]
August 21, 2014

Ontario Government Issues RFP for Investment Dealer Services
Refer to blog posting dated August 20, 2014

Exemption from the Provisions of Rules 91-507 Trade Repositories and Derivatives Data Reporting for IIROC Registered Dealers [PDF]
August 13, 2014

IIAC Request to IIROC for Extension – Order Execution Services – Client Contracts [PDF]
August 6, 2014

IIAC 2014 Pre-Budget Submission – House of Commons Standing Committee [PDF]
August 6, 2014

IIAC Letter to CSA on NI 21-101 – Marketplace Operation [PDF]
July 25, 2014

IIAC Response to IIROC re Lower Minimum Capital Requirements [PDF]
July 9, 2014

IIAC Response to IIROC re Proposed Guidance on Marketplace Thresholds [PDF]
July 3, 2014

IIAC Letter to Finance and CRA re “Carrying on a Business” and Borrowing Within TFSAs [PDF]
July 3, 2014

IIAC Response to IIROC re Provisions and Guidance Respecting Order Execution Services [PDF]
June 23, 2014

IIAC Response to OSC re: Prospectus Amendments [PDF]
June 18, 2014

IIAC Response re: Multilateral Instrument Crowdfunding[PDF]
June 18, 2014

IIAC Response re: Multilateral Instrument OM Exemption [PDF]
June 18, 2014

IIAC Response to IIROC Fee Model Guideline Amendments [PDF]
June 10, 2014

IIAC Responds to IIROC Proposed Guidance on Underwriting Due Diligence [PDF]
June 4, 2014

IIAC Supports IIROC Guidance Clarifying Part Time CFOs [PDF]
June 2, 2014

IIAC Comments on IIROC Personal Financial Dealings Rule [PDF]
May 28, 2014

IIAC Responds to CSA re: Proposed Changes to Accredited Investor and Minimum Amount Exemptions [PDF]
May 28, 2014

CBRF Response to IOSCO Questionnaire [PDF]
May 28, 2014

IIAC Response to OSC Statement of Priorities 2014-2015 [PDF]
May 27, 2014

IIAC Response to Implementation of Stage 3 of Point of Sale Disclosure [PDF]
May 26, 2014

IIAC Pre-budget Letter to Quebec’s Minister of Finance Re Recommendations to Revive Quebec’s IPO Market (available only in French) [PDF]
May 16, 2014

IIAC Response to Proposed Amendments to NI 45-106 – Short Term Debt Prospectus Exemptions [PDF]
April 23, 2014

IIROC Response to IIAC Letter on Wash Trades [PDF]
April 21, 2014

IIAC Submission to IIROC re Wash Trades March 14 – posted April 21 [PDF]
April 21, 2014

IIAC-IIROC and CSA Response on CRM2 2015 and 2016 Disclosure Requirements [PDF]
April 10, 2014

IIAC Letter to Alberta Treasury Board and Finance on PRPPs and RRSPs [PDF]
April 4, 2014

IIAC Letter to Alberta Government Re Retirement Plan Hardship Unlocking and PRPP [PDF]
April 4, 2014

IIAC Letter to BC Deputy Attorney General Re: Irrevocable Beneficiary Provisions [PDF]
March 26, 2014

IIAC Response to OSC Rule 24-503 Clearing Agency Requirements [PDF]
March 19, 2014

Canada’s Investment Industry: Protecting Senior Investors – Compliance, Supervisory and Other Practices When Serving Senior Investors [PDF]
March 18, 2014

IIAC Letter to CRA on Proposed T1135 Changes for 2014 [PDF]
March 14, 2014

IIAC Letter to IRS re REG-120282-10 (Dividend Equivalents) Supplemental Comments [PDF]
March 12, 2014

IIAC Letter to CSA on Notice 81-324 – Mutual Fund Risk Classification [PDF]
March 12, 2014

IIAC Response to IIROC’s Proposed Debt Securities Transaction Reporting Rule [PDF]
March 10, 2014

IIAC Submission to IIROC re Single Stock Circuit Breakers 2014 [PDF]
March 10, 2014

IIAC Response to CSA re Proposed Amendments to NI 31-103 [PDF]
March 4, 2014

IIAC E-Mail to Revenu Quebec re Relevé 18 (RL-18) [PDF]
February 23, 2014

IIAC Letter to IRS re Notice 2014-14 Providing Timing Relief for Application of 871(m) Regulations to ELIs [PDF]
February 20, 2014

IIAC Response to Republication of Proposed Consolidation of IIROC Enforcement, Procedural, Examination and Approval Rules [PDF]
February 11, 2014

IIAC Letter to IIROC and CSA on CRM2 July 15 2014 Disclosure Requirements [PDF]
February 10, 2014

IIAC Response re: Notice 13-0269 Revised Sanction Guidelines [PDF]
February 3, 2014

IIAC Response to Finance re: Financial Planning Consultation [PDF]
January 31, 2014

IIAC Response to Ontario Finance on Ontario PRPPs [PDF]
January 20, 2014

IIAC Response to CSA re Proposed Existing Security Holder Exemption [PDF]
January 20, 2014

IIAC Submission to IIROC re: Proposed Provisions Respecting Order Execution Services as a Form of Third Party Electronic Access to Marketplaces [PDF]
January 10, 2014

IIAC letter to BCSC re: Amendments to Conditions of Registration for BC Dealers that Trade in the U.S. OTC Markets [PDF]
December 20, 2013

Joint industry submission to IRS on proposed revisions to IRS W-8 Forms [PDF]
December 19, 2013

IIAC-BLG Letter on CDS Clearing and Depository Services Rules Review [PDF]
December 6, 2013

IIAC Brief for House of Commons Standing Committee on Finance [PDF]
November 14, 2013

IIAC Submission to the CSA Regarding Consultation Paper 54-401 – Review of the Proxy Voting Infrastructure [PDF]
November 13, 2013

IIAC-Assistant Commissioner Bennett (CRA) Follow-up Letter on T5103+T5013A Combination and XML Implementation [PDF]
November 12, 2013

IFIC-IIAC Submission to CSA Re-Consultation Paper 33-403 [PDF]
November 11, 2013

IIAC Submission Proposed Guidance on Marketplace and Average Price Trade Confirmation Disclosure [PDF]
November 4, 2013

IIAC Letter to FSCO on Ontario Financial Hardship Unlocking Guide [PDF]
October 28, 2013

IIAC-Commissioner Treusch (CRA) Letter Requesting Meeting on T5103+T5013A Combination and XML Implementation [PDF]
October 10, 2013

IIAC Response – Payday Loans Act 2008 Proposed Amendments [PDF]
September 27, 2013

IIAC Letter to FSCO on Ontario Hardship Unlocking Process and Forms [PDF]
August 31, 2013

IIAC Submission to OBSI re: Terms of Reference [PDF]
August 12, 2013

IIAC Letter to Federal Department of Finance re: Broker Warrants [PDF]
August 9, 2013

IIAC Pre-Budget Submission to House of Commons Finance Committee 2013-2014 [PDF]
August 2, 2013

IIAC Letter to CSA re Proposed Modernization of Investment Fund Product Regulation Amendments [PDF]
August 2, 2013

IIAC-IFIC Letter to Revenue Quebec on Suggested QESI Improvements [PDF]
July 31, 2013

IIAC Letter to Finance Requesting Change to Income Tax Act to Avoid Excess Penalization of Trustees and Dealers Due to Taxpayer Activities [PDF]
July 18, 2013

IIAC Submission re Take Over Bids and Early Warning 2013 [PDF]
July 12, 2013

IIAC Response to CSA 91-407 Derivatives: Registration Consultation Paper [PDF]
June 17, 2013

IIAC Letter to the CRA re: Improvements to Registered-Plan-Related Withholding Remittances [PDF]
June 6, 2013

IIAC Response to IIROC Debt Securities Transaction Reporting Proposal [PDF]
May 21, 2013

IIAC Response to the CSA re: Mutual Fund Fees [PDF]
April 12, 2013

IIAC and IFIC Letter to CRA Proposing CRA-Financial Industry Advisory Group [PDF]
March 18, 2013

IIAC Letter to CSA re Futures Regulatory Regime for Unregistered FCM Entities [PDF]
March 8, 2013

IIAC-OSC Letter on Consultation Paper on New Capital-Raising Exemptions [PDF]
March 8, 2013

IIAC Letter to Finance Re Draft Technical Amendments [PDF]
February 22, 2013

The IIAC Responds to CSA Consultation Paper 33-403 – Exploring a Best Interest Standard for Advisors [PDF]
February 22, 2013

IIAC Response to Multilateral Instrument 45-311 Re Offering Memorandum Exemption [PDF]
February 20, 2013

IIAC Letter to CSA re OBSI Jurisdiction Expansion [PDF]
February 14, 2013

IIAC Response to CSA Staff Consultation Paper 91-301 – Model Provincial Rules re Derivatives Product Determination and Reporting [PDF]
February 11, 2013

IIAC Letter to CSA re Market Data Pricing 2013 [PDF]
February 8, 2013

IIAC Response Re Proposed IIROC Provisions Respecting Third Party Electronic Access to Marketplaces [PDF]
January 23, 2013

IIAC Letter to Ontario Finance Minister Dwight Duncan on PRPPs [PDF]
January 21, 2013

IIAC Submission Re IIROC’s Guidance on Clearing Arrangements [PDF]
Jan 20, 2013

IIAC Response Re IIROC’s Outsourcing Arrangements [PDF]
January 18, 2013

IIAC Letter to OSC on Notice and Fee re Registrants’ Securities or Assets Being Acquired [PDF]
January 16, 2013

IIAC Letter to FSCO Regarding Hardship Unlocking [PDF]
January 16, 2013

IIAC Letter to the Honourable Marie-Claude Blais, Minister of Justice and Attorney General, re Financial Services Regulatory Agency [PDF]
December 20, 2012

IIAC responds to IIROC Concept Paper on the Feasibility of Portfolio Margining [PDF]
December 17, 2012

IIAC Letter to CRA with Suggestions Regarding Small Business Consultations [PDF]
December 7, 2012

Joint Industry Submission to IRS re: Electronic Transmission of W-8 Forms [PDF]
December 3, 2012

IIAC Letter to Senate Standing Committee on National Finance re Bill C-45 as it Relates to PRPPs [PDF]
November 29, 2012

IIAC Submission to the OSC in Response to the Request for Comments on Proposed Amendments to OSC Rule 13-502 Fees and Companion Policy 13-502CP Fees [PDF]
November 26, 2012

Joint Industry Submission re FATCA Grandfathering Date [PDF]
November 21, 2012

IIAC Submission re Impact of Financial Transaction Taxes by Foreign Jurisdictions on Canada [PDF]
November 19, 2012

IIAC Response to IIROC Compensation Structures for Retail Investment Accounts [PDF]
November 14, 2012

IIAC Response to Finance on Second Tranche of PRPP Regulations [PDF]
November 13, 2012

Letter from IIAC to Revenue Quebec regarding 2012 Year Reporting Concerns [PDF]
November 12, 2012

IIAC Response to BCSC Proposed Conditions of Registration for BC Dealers Trading OTC Securities [PDF]
November 2, 2012

Inter-Association Letter to Revenu Quebec re RL15s and RL16s (Foreign Income and Taxes) [PDF]
November 2, 2012

IIAC Letter to House of Commons Finance Committee on Bill C-45 as it Relates to Pooled Registered Pension Plans (PRPPs) [PDF]
November 1, 2012

IIAC 2013 Pre-Budget Remarks to House of Common Standing Committee on Finance [PDF]
October 24, 2012

IIAC Letter re Unclaimed Intangible Property Program Consultation [PDF]
October 22, 2012

IIAC Response to Manipulative and Deceptive Trading RFC [PDF]
October 15, 2012

IIAC Letter to FCAC re Dealer Concerns with DTI Regulations [PDF]
October 9, 2012

IIAC Response to IIROC Restricted Dealer Proposal [PDF]
October 9, 2012

IIAC Response to IIROC on Borrowing for Investment Purposes – Suitability and Supervision [PDF]
October 2, 2012

IIAC Response to BCBS-IOSCO Consultative Document re Margin Requirements for Non-Centrally Cleared Derivatives [PDF]
September 28, 2012

IIAC Response to IIROC Electronic Trading Rules [PDF]
September 24, 2012

Joint Industry Submission to IRS re: Draft Certificates W-8IMY, W-8ECI and W-8EXP [PDF]
September 20, 2012

IIAC Submission re Proposed Amendments to NI 31-103 Cost Disclosure Performance Reporting and Client Statements [PDF]
September 14, 2012

IIAC Submission to CSA on Stage 2 on Point of Sale Disclosure for Mutual Fund [PDF]
September 11, 2012

IIAC Comments on Proposed Pooled Registered Pension Plan (PRPP) Regulations [PDF]
September 10, 2012

IIAC Letter to CFTC Regarding Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act [PDF]
August 27, 2012

ICSA Letter to CFTC on the Proposed Interpretive Guidance on the Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act (RIN 3038–AD57) [PDF]
August 27, 2012

IIAC Letter to CRA re Clarifying Requirements to Pay [PDF]
August 23, 2012

IIAC Responds to CFTC Exemptive Order Regarding Swaps [PDF]
August 13, 2012

IIAC Response to Private Member Bill on Reporting to the CRA [PDF]
August 13, 2012

IIAC Letter to CRA Re Multi-Payment Tax Recovery Forms [PDF]
August 9, 2012

ICSA Letter to Mark Carney, Chairman, Financial Stability Board [PDF]
August 8, 2012

IIAC Letter to CRA Regarding Use of W8-BENs as NR301 Equivalents [PDF]
August 8, 2012

IIAC Response to IIROC Marketplace Thresholds [PDF]
August 8, 2012

IIAC Pre-Budget Submission to the House of Commons Finance Committee [PDF]
July 31, 2012

IIAC Letter to Minister Flaherty on Concerns with PRPPs [PDF]
July 30, 2012

IIAC Letter to CRA Regarding De-Registering TFSAs [PDF]
July 27, 2012

IIAC responds to Government consultations on Venture Capital [PDF]
July 27, 2012

IIAC Response to “Off Marketplace” Trades [PDF]
July 11, 2012

IIAC Response to 2012 OBSI Loss Assessment Consultation [PDF]
July 9, 2012

IIAC-IFIC Letter to Revenu Québec on Relevé 16 for Foreign Capital Gains and Investment Income [PDF]
June 21, 2012

IIAC Response to IIROC Transparency of Short Selling and Failed Trades [PDF]
May 31, 2012

IIAC Letter to CRA regarding New T5013 Requirements for Nominees [PDF]
May 29, 2012

IIAC Letter to Finance Minister on Designated Stock Exchanges [PDF]
May 24, 2012

IIAC Letter to Ontario Ministry of Consumer Services on Personal Property Security Act Reform [PDF]
May 17, 2012

IIAC Request to CRA re Eliminating Un-Cost-Effective Correction Reporting [PDF]
May 17, 2012

IIAC Response to IIROC Proposed Guidance on Short Sale and Short Marking Exempt Order Designations [PDF]
May 2, 2012

Joint Industry Submission on REG-121647-10 [PDF]
April 30, 2012

IIAC Comments on Proposed Regulations (REG-121647-10) re Capital Markets Business Sector [PDF]
April 30, 2012

IIAC Request to CRA re RRSP and RRIF Contract Numbers [PDF]
April 20, 2012

IIAC Comments on Proposed U.S. Treasury Regulations on Dividend Equivalents REG 120282-10 [PDF]
April 11, 2012

IIAC Comments on Proposed Cost Basis Regulations for Debt Instruments and Options [PDF]
March 14, 2012

IIAC’s comments on AMF’s notice regarding compensation of consumers of financial products and services (French Only) [PDF]
March 13, 2012

IIAC Letter to House of Commons Finance Committee on Pooled Registered Pension Plans (PRPPs) [PDF]
March 5, 2012

IIAC Submission Re AML Consultation Paper [PDF]
February 29, 2012

IIAC Response to Notice 45-401 Prospectus Exemptions [PDF]
February 29, 2012

Comments on Obligations Pertaining to Supervision Amendments to Article 4002 [PDF]
February 24, 2012

IIAC Response to Pre Marketing Proposals 2012 [PDF]
February 23, 2012

IIAC Letter to Bourse de Montreal Concerning Circulaire 008-2012 (French only, English version available soon) [PDF]
February 24, 2012

IIAC Letter to Minister of Finance with Comments on PRPP Income Tax Act Amendments [PDF]
February 16, 2012

IIAC Response Letter re Circuit Breakers [PDF]
February 13, 2012

IIAC Letter to Securities Commissions [PDF]
January 31, 2012

IIAC Response to CSA Consultation Paper 91-403 on Derivatives: Surveillance and Enforcement [PDF]
January 25, 2012

IIAC Letter to CRA Regarding NR301, 302 and 303 Forms [PDF]
January 22, 2012

IIAC Letter to CSA on CTO Database [PDF]
January 3, 2012

IIAC Comments on the Impact of the Proposed Volcker Rule on the Marketplace for Canadian Government Securities [PDF]
December 21, 2011

IIAC Responds to Department of Finance Consultation Paper on Proposed Amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations on Ascertaining Identity [PDF]
December 16, 2011

IIAC Letter to CRA regarding NR301, 302, and 303 Forms [PDF]
December 16, 2011

IIAC Opening Remarks to Standing Senate Committee on National Finance on Bill C-13 re Registered Plan Anti-Avoidance Rules – December 6, 2011 [PDF]
December 9, 2011

IIAC Letter to Senate Committee on Bill C-13 Anti-avoidance and Related Registered Plan Provisions [PDF]
December 2, 2011

IIAC Letter to Treasury [PDF]
November 23, 2011

Review of Minimum Amount and Accredited Investor Exemptions [PDF]
November 18, 2011

IIAC Response to CSA – POS- Nov 10 2011 [PDF]
November 10, 2011

Comments on the Proposed Acquisition of TMX Group, Alpha and CDS by Maple Group Acquisition Corporation [PDF]
November 9, 2011

IIAC Requests Permanent Exemption from SEC Rule 17g-5 [PDF]
November 2, 2011

Bill C-13 to Recommendations House of Commons Standing Committee on Finance on RRSP/RRIF Anti-Avoidance and Other Rules [PDF]
October 31, 2011

IIAC Response to Dark Liquidity Proposals [PDF]
October 25, 2011

International Council of Securities Associations (ICSA) Letter to European Commission on a Global Financial Transaction Tax [PDF]
October 27, 2011

IIAC Pre-Budget Testimony to the House of Commons Standing Committee on Finance [PDF]
October 27, 2011

IIAC Letter to Minister of Finance with 2012 Pre-Budget Recommendations [PDF]
October 3, 2011

IIAC Letter to Finance and CRA Regarding RRSP and RRIF Anti-Avoidance Proposals [PDF]
September 23, 2011

IIAC Responses to Free-Form Questions in Red Tape Reduction Commission Online Questionnaire –September 23, 2011 [PDF]
September 23, 2011

IIAC Responds to CSA on Cost Disclosure and Performance Reporting under National Instrument 31-103 [PDF]
September 20, 2011

IIAC Response: OTC Trade Repository [PDF]
September 12, 2011

IIAC Submission to CRTC on Do Not Email Regulation [PDF]
September 7, 2011

IIAC Submission to Industry Canada on Do Not Email Regulation [PDF]
September 7, 2011

Proposed Guidance on the Guarantee by a Participant of a Trade Price for a Client Order [PDF]
September 2, 2011

IIAC Responds to CSA Proposal on Enhanced Oversight of Securitized Products [PDF]
August 31, 2011

IIAC Letter – Proposed IIROC Debt Market Rule Rewrite [PDF]
August 25, 2011

IIAC Submission to CRA Requesting Delay in Implementation of NR 301 302 and 303 Forms [PDF]
August 24, 2011

IIAC Letter to Commission de l’Accès à l’Information regarding Bourse LOPR Requirements [PDF]
August 23, 2011

IIAC Pre-Budget Submission to House of Commons Standing Committee on Finance [PDF]
August 8, 2011

IIAC Letter to Finance on Tax Aspects of Pooled Registered Pension Plans (PRPPs) [PDF]
August 3, 2011

IIAC Letter to Jeremy Rudin ADM Finance re PRPP Framework [PDF]
July 29, 2011

IIAC Letter to Junior Finance Minister Menzies and Provincial Ministers on PRPP [PDF]
July 28, 2011

IIAC Response to OBSI Loss Assessment Consultation [PDF]
July 25, 2011

IIAC Submission to the Bourse on June 9 Response on Large Open Position Reporting (LOPR) [PDF]
July 22, 2011

IIAC Letter to the Bourse and AMF on Draft Large Open Position Reporting (LOPR) Rule Amendments [PDF]
July 18, 2011

IIAC Submission to Finance and CRA Regarding Budget and Ways and Means Motion RRSP Anti-Avoidance Provisions [PDF]
July 13, 2011

IIAC Submission to IIROC on Outside Business Activities [PDF]
July 11, 2011

IIAC Comments on NI 23-103 Electronic Trading and Direct Electronic Access to Marketplaces [PDF]
July 8, 2011

IIAC Letter to Finance with Additional Information re: Reason for Non-MTM Tax Treatment of Broker Warrants [PDF]
July 7, 2011

IIAC Comments on Amended National Policy 11-201 [PDF]
June 29, 2011

Proposed Amendments to NI 21-101 Marketplace Operation and NI 23-101 Trading Rules [PDF]
June 14, 2011

An Economic Study of Securities Market Data Pricing by Canadian Trading Venues [PDF]
June 6, 2011

IIAC Submission to U.S. Treasury and IRS on Notice 2011-34 (FATCA) [PDF]
June 7, 2011

IIAC Letter to Minister of Finance Proposing Tax-Reporting Efficiencies for Businesses and Government and Other Issues [PDF]
June 2, 2011

IIAC Letter to Minister of National Revenue Proposing Efficiencies for Businesses and Government in Tax Administration [PDF]
May 31, 2011

IIAC Letter to Federal Department of Finance Suppporting Hong Kong Tax Treaty Negotiations [PDF]
May 31, 2011

IIAC Letter to Bourse de Montreal on Draft LOPR Confidentiality Agreement [PDF]
May 27, 2011

IIAC Response Letter re: Draft Guidance Short Sale and Short Marking Exempt [PDF]
May 26, 2011

IIAC Response Letter re: Short Sale Regs [PDF]
May 26, 2011

IIAC Letter to Bourse de Montreal on Large Open Position Reporting (LOPR) [PDF]
May 20, 2011

IIAC Letter to Bourse de Montreal on Large Option Position Reporting(LOPR) [PDF]
April 12, 2011

IIAC Submission to Federal Red Tape Reduction Commission [PDF]
March 31, 2011

IIAC Response to OSC Staff Notice 54-701 [PDF]
March 31, 2011

IIAC Letter to B.C. Finance Minister on HST Consultations [PDF]
March 10, 2011

IIAC Remarks to the Red Tape Reduction Commission [PDF]
March 10, 2011

IIAC Submission to the Ontario Select Committee on the TMX-LSE Merger [PDF]
March 9, 2011

IIAC Remarks to the Ontario Select Committee on the TMX-London Stock Exchange Merger [PDF]
March 9, 2011

Proposals to implement the core principles of the Client Relationship Model [PDF]
March 7, 2011

IIAC Letter to Finance Urging Fair Tax Treatment of Broker Warrants [PDF]
February 16, 2011

IIAC Submission on Pooled Registered Pension Plans (PRPPs) [PDF]
February 16, 2011

IIAC Letter to B.C. Finance Minister re Double Taxation Agreement with Hong Kong [PDF]
February 14, 2011

IIAC Letter to Finance Minister Flaherty Encouraging Acceleration of Hong Kong Tax Treaty Negotiations [PDF]
February 2, 2011

Industry Response to CSA CP 91 401 on Over the Counter Derivatives Regulation in Canada [PDF]
January 14, 2011

IIAC Submission to Joint Regulators on Dark Liquidity [PDF]
January 10, 2011

Request for Comments: Rules Notice 10-0266 “Plain language rule re-write project: Dealing with clients, Proposed Rules 3400, 3900” (the “Notice”) [PDF]
January 7, 2011

Letter to OBSI Re 2010 Terms of Reference [PDF]
November 30, 2010

Submission on AML Requirements [PDF]
November 17, 2010

IIAC Comments on U.S. FATCA&HIRE Act Implementation [PDF]
November 9, 2010

Pre-Budget Consultations House of Commons Standing Committee on Finance [PDF]
October 21, 2010

Administrative Notice Guidance Note Anti Money Laundering Compliance Guidance [PDF]
October 18, 2010

Rules Notice 10-0227 – Award Limit and Costs Awards for IIROC Arbitration Program [PDF]
October 6, 2010

Proposed Amendments to National Instrument 31103 National Instrument 33109 and OSC Rule 33506 the Amendments [PDF]
September 30, 2010

Comment Paper to the CSA on National Instrument 54-101 – Securityholder Communications Process in Canada [PDF]
August 31, 2010

Request for Comments: Rules Notice 10-0155 “Proposed Personal Financial Dealing and Outside Business Activities Proposals” [PDF]
August 27, 2010

IIAC Recommendations to the House of Commons Standing Committee on Finance [PDF]
August 12, 2010

U.S. Taxation of Substitute Dividends [PDF]
July 9, 2010

IIROC Request for comments: Rules Notice 10-0163 “Proposed over-the-counter securities fair pricing rule and confirmation disclosure requirements” [PDF]
July 8, 2010

IIAC Comments on IIROC’s Proposed Fee Model [PDF]
June 22, 2010

Request for Comments: Rules Notice 10-0085 “Plain language rule rewrite project – Proposed Rule 3100, Business Conduct and Proposed Rule 3200, Client Accounts” (the “Notice”) [PDF]
June 22, 2010

Request for Comments: Rules Notice 10-0097 “Trade Confirmation and Matching Requirements” [PDF]
June 8, 2010

IIAC Letter to L. Kottachchi, Finance Canada re Bill C9 Excise Tax Act Amendments [PDF]
June 3, 2010

Cross-Border Clearing and Settlement Arrangements [PDF]
May 31, 2010

IIAC Response to IIROC Notice on Locked and Crossed Markets [PDF]
May 21, 2010

Happy 40th CDS [PDF]
May 13, 2010

IIAC Provides Recommendations to Federal Government on Retirement Income Adequacy [PDF]
May 5, 2010

Request for comments on draft “Requirements and Best Practices for distribution of non-arm’s-length investment products” [PDF]
May 3, 2010

IIAC Letter to I. Bastasic, CRA re CRA Notice 250 [PDF]
April 21, 2010

Task Force on Financial Literacy [PDF]
April 19, 2010

Letter to CRTC – CRTC 2010-130 – Unsolicited Telecommunications Rules – Financial and insurance products and services offered to existing clients [PDF]
April 6, 2010

Ontario Budget [PDF]
March 26, 2010

IIAC Recommendations for Regulation of Direct Market Access and Sponsored Access Arrangements [PDF]
March 17, 2010

IIAC Letter to Finance Canada ADM on CRA Notice 250 [PDF]
March 16, 2010

IIAC Comments on IIROC Arbitration Program [PDF]
March 16, 2010

Summary of 2010 Key Budget Points for IIAC Members [PDF]
March 5, 2010

IIAC Response to Request for Comments Regarding Statement of Priorities For Fiscal Year Ending March 31, 2011 [PDF]
February 19, 2010

Pre-Budget Recommendations [PDF]
February 18, 2010

IIAC Comments on Proposed Basis Reporting Regulations [PDF]
February 8, 2010

IIAC Response to CSA Request for Comment on NI 24-101 – Institutional Trade Matching [PDF]
January 28, 2010

IIAC Response to CSA Consultation Paper 23-404 Dark Pools, Dark Orders and Other Developments in Market Structure in Canada [PDF]
December 21, 2009

IIAC Comments on IIROC Know-Your Client (KYC) and Suitability Guidelines [PDF]
December 16, 2009

IIAC Remarks to Ontario Standing Committee on Finance and Economic Affairs Regarding Bill 218 [PDF]
December 7, 2009

ICSA Submission to BCSC Regarding Expanded Industry Consultation with the BCSC [PDF]
December 2, 2009

ICSA Response to IOSCO on the Transparency of Structured Finance Products [PDF]
November 13, 2009

IIAC Letter to CIPF Regarding Fees for Type 2 Introducers [PDF]
October 30, 2009

IIAC 2009 Pre-Budgetary Consultations to the House of Commons Standing Committee on Finance [PDF]
October 22, 2009

IIAC Letter to the CSA Regarding the Implementation of Point of Sale Disclosure for Mutual Funds [PDF]
October 16, 2009

IIAC Letter to ON Minister of Finance and Revenue Regarding Sales Tax Harmonization in Ontario [PDF]
October 15, 2009

IIAC Letter to BC Ministry of Finance and Deputy Premier Regarding Sales Tax Harmonization in British Columbia [PDF]
October 15, 2009

IIAC Comments on the Canadian Council of Insurance Regulators (CCIR) Consultation Document on the Implementation of Joint Forum [PDF]
October 11, 2009

IIAC Comments on Proposed Amendments to MFDA Rule 2.4.1 [PDF]
September 17, 2009

IIAC Letter to CRA Regarding Forms NR301, NR302 and NR303 [PDF]
September 11, 2009

IIAC Letter to IIROC Regardig IIROC Proposed Rule 3900 [PDF]
August 24, 2009

IIAC 2009 Pre-Budget Recommendations to the House of Commons Standing Committee on Finance [PDF]
August 13, 2009

IIAC Letter to the House of Commons Standing Committee on Industry Regarding Bill C-27 – The Electronic Commerce Protection Act (ECPA) [PDF]
August 12, 2009

IIAC Letter to the Canadian Minister of Heritage Regarding CBC Sunday Segment [PDF]
July 29, 2009

IIAC Letter to CBC President [PDF]
July 29, 2009

IIAC Letter to OSC and IIROC Regarding the Client Relationship Model (CRM) [PDF]
July 23, 2009

ICSA Response to IOSCO on the Impact on and Responses of Emerging Markets to the Financial Crisis [PDF]
July 21, 2009

IIAC Comments on IIROC Rules Notice 09-0109 – Proposed Over-the-counter Securities Fair Pricing Rule and Confirmation Disclosure Requirements [PDF]
July 14, 2009

IIAC Letter to the OSC and IIROC Regarding the Proposed Amendments to Dealer Member Rule 1300.1 – Trading in Securities of US OTC Issuers [PDF]
July 13, 2009

IIAC Letter to the Halifax Chronicle Herald Regarding and Article on the Federal Initiative for a Single Securities Regulator [PDF]
July 13, 2009

ICSA Submission to the BIS Regarding Industry Consultation with the Financial Stability Board [PDF]
June 19, 2009

IIAC Response to CSA Letter Regarding Marketplace Fees for Access, Trading and Data [PDF]
June 16, 2009

ICSA Submission to IOSCO Regarding IOSCO’s Consultation Report on Unregulated Financial Markets and Products [PDF]
June 15, 2009

IIAC Comments on TSX Security Holder Approval Requirements for Acquisitions [PDF]
May 4, 2009

Ian Russell (IIAC) Presentation to the Vancouver Board of Trade – Resilience of Canada’s Financial Institutions and Markets [PDF]
April 23, 2009

IIAC Remarks – Testimony to the House of Commons Standing Committee on Finance [PDF]
April 2, 2009

Ian Russell (IIAC) Presentation to the Calgary Chamber of Commerce – Turbulent Markets Demand Major Changes [PDF]
March 24, 2009

IIAC Letter to the Ontario Government Regarding Sales Tax Harmonization in Ontario [PDF]
March 18, 2009

IIAC Letter to the Government of Ontario Regarding Sales Tax Harmonization [PDF]
March 18, 2009

IIAC QI Committee Comments on IRS Notice 2009-17 – Information Reporting of Customer’s Basis in Securities Transactions [PDF]
March 16, 2009

IIAC Letter Regarding IIROC Amendments to Complaint Handling Requirements and to IIROC Dealer Member Rules 19, 37 and 2500 [PDF]
March 16, 2009

Ian Russeell (IIAC) Speech to the HAlifax Chamber of Commerce – Turbulent Markets Demand Major Change [PDF]
March 4, 2009

IIAC Comments on IRS Announcement 2008-98 on Proposed Ammendments [PDF]
February 26, 2009

IIAC Comments on CSA Consultation Paper 11-405 – Securities Regulatory Proposals Stemming from 07-08 Turmoil and its Effect on ABCP Markets in Canada [PDF]
February 17, 2009

IIAC 2009 Ontario Pre-Budget Recommendations [PDF]
January 26, 2009

IIAC Letter to CSA Regarding IIROC Notice 08-0163 – Provisions Respecting Implementation of Trade-Through Protection [PDF]
January 9, 2009

IIAC Letter on Securities Basis Reporting by QIs [PDF]
January 9, 2009

IIAC 2009 Pre-Budget Remarks Before Conservative Members of the Finance Committee [PDF]
January 8, 2009

IIAC Letter Regarding IIROC Amendments to Implement the CSA Registration Reform Project [PDF]
December 22, 2008

IIAC Letter to OSC Regarding Proposed Revocation and Replacement of OSC Rule and Companion Policy 13-502 Fees [PDF]
December 19, 2008

IIAC Comments on IIROC Draft Guidance Note – Best Practices for Product Due Diligence [PDF]
December 16, 2008

IIAC Letter to IRS Regarding the QI Treatment of TFSAs [PDF]
October 21, 2008

IIAC Letter to the Editor of the Invesment Executive [PDF]
October 6, 2008

IIAC Letter to the CSA Regarding Proposed Policy and Amendments to the Passport System in the Canadian Securities Marketplace [PDF]
September 12, 2008

IIAC Comments on SEC Proposed Rules for Exemption of Certain Foreign Brokers or Dealers [PDF]
September 8, 2008

IIAC Letter to BCSC and MFDA Regarding the Client Relationship Model (CRM) [PDF]
August 18, 2008

IIAC Letter to Financial Services Commission of Ontario Regarding Point of Sale Disclosure for Mutual Funds and Segregated Funds [PDF]
August 12, 2008

IIAC Recommendations to the HoC Standing Committee on Finance Regarding Reforms to Canada’s Capital Gains Tax Framework [PDF]
August 7, 2008

IIAC Submission to the Expert Panel on Securities Regulation [PDF]
July 2008

IIAC Letter to DoF on Broker Warrants [PDF]
July 10, 2008

IIAC Letter to the OSC Regarding National Instrument 54-101 Stakeholder Consultations [PDF]
June 27, 2008

IIAC Request to Committee on Finance for Meeting on Basis Proposals [PDF]
June 6, 2008

IIAC Request for Meeting on Basis Reporting Proposals [PDF]
June 6, 2008

IIAC Letter to the Quebec Ministerial Committee on Economic Prosperity and Sustainable Development Recommending the Use of Non-Driver’s Driver’s License [PDF]
June 6, 2008

IIAC Letter to Quebec Government Regarding Recommendations on Regulatory Streaming [PDF]
June 4, 2008

IIAC Comments to the Senate Banking Committee Regarding Tax-Free Savings Accounts (TFSAs) [PDF]
May 30, 2008

IIAC Response to Proposed National Instrument 31-103 and Companion Policy 31-103 – Registration Requirements [PDF]
May 28, 2008

IIAC Letter to the Ministry of Finance Regarding the Consultation Draft of Amendments to the Ontario Securities Act [PDF]
May 28, 2008

Ian Russell (IIAC) Presentation to House of Commons Standing Committee on Finance Regarding TFSAs [PDF]
May 26, 2008

IIAC Letter to IDA and OSC Regarding the Client Relationship Model (CRM) Rules [PDF]
May 21, 2008

IIAC Letter Regarding the Extension in Definition of Qualified Securities for the Purpose of Securities Lending [PDF]
May 2, 2008

IIAC Letter to DoF on Reducing Administrative Burden and Increasing Competitiveness [PDF]
April 30, 2008

IIAC Letter to DoF Regarding TFSA [PDF]
April 23, 2008

IIAC Submission to Finance – A Capital Idea [PDF]
April 4, 2008

Ian Russell (IIAC) Speech to the Montreal Economic Institute Regarding Canadian Securities Regulation [PDF]
March 20, 2008

Ian Russell (IIAC) Presentation to the Calgary Chamber of Commerce – Seizing Global Opportunities [PDF]
March 5, 2008

IIAC Comments on Basis Reporting Proposals Under Revenue Code S. 6045 [PDF]
February 22, 2008

IIAC Letter to the Competition Policy Review Panel Regarding Sharpening Canada’s Edge [PDF]
February 20, 2008

IIAC Letter to OBSI Regarding Proposed Amended Terms of Reference for OBSI [PDF]
January 31, 2008

IIAC Letter to DoF Regarding 2008 Pre-Budget Recommendations [PDF]
January 31, 2008

IIAC Letter to IDA Regarding the Client Relationship Model (CRM) [PDF]
January 29, 2008

IIAC Letter to OIRA on Proposed Tender Offer Changes [PDF]
January 18, 2008

IIAC Letter to the IDA Regarding CICA Requirement for Audit for Introducers and the Section 5970 Report [PDF]
January 16, 2008

IIAC Letter to IRS Regarding Proposed Regulations (REG-140206-06) [PDF]
January 16, 2008

IIAC Letter to IIROC and the CSA Regarding IIROC Notice 08-0163 – Provisions Respecting the Implementation of Trade-Through Protection [PDF]
January 9, 2008

IIAC Letter to CSA Regarding Proposed Amendments to NI 21-101 and NI 23-101 [PDF]
January 9, 2008

2007-12-28E IIAC Comments to DTC on Proposed Tender Offer Changes [PDF]
December 28, 2007

IIAC Letter to BCSC Regarding Proposed Instrument 51-509 [PDF]
December 19, 2007

IIAC Letter to Standing Senate Committee on National Finance Regarding Income Funds and Client T3 and T5013 Income Trust Tax Reporting [PDF]
December 13, 2007

IIAC Comments on TSX Security Holder Approval Requirements for Acquisitions [PDF]
December 12, 2007

IIAC Submission to the CRA – The Taxing Truth [PDF]
November 21, 2007

IIAC Submission to Industry Canada – Investment in Canada’s Interest [PDF]
November 21, 2007

Ian Russell (IIAC) Presentation to NBCN – Down The Rabbit Hole [PDF]
October 19, 2007

IIAC Letter to Market Regulation Services Regarding Market Integrity Notice 2007-017 – Provisions Respecting Short Sales and Failed Trades [PDF]
October 9, 2007

IIAC Letter to the Joint Forum Project Office Regarding Proposed Framework 81-406 – Point of Sale Disclosure for Mutual Funds and Segregated Funds [PDF]
October 5, 2007

IIAC Letter to DoF Regaring the Association’s Support of Updated Canadian Securities Transfer and Related Law [PDF]
September 14, 2007

IIAC Letter to SEC Regarding Free Trade in Securities [PDF]
September 10, 2007

IIAC Comments on Form 1042-S [PDF]

August 23, 2007

IIAC Letter to DoF Regarding Excessive and Unwanted Disclosure Material [PDF]
August 17, 2007

IIAC Letter to the CSA and MRS on the Joint Notice on Trade-Through Protection, Best Escenution and Access to Marketplaces [PDF]
July 19, 2007

IIAC Letter Regarding Unwanted Mail [PDF]
July 11, 2007

IIAC Comments on IRS Draft W-8BEN and Instructions [PDF]
July 9, 2007

IIAC Letter to the IDA Expressing Concern Abut the Process By Which IDA Notices are Issued [PDF]
July 3, 2007

IIAC Letter to the CSA Regarding Proposed National Instrument 31-103 and Companion Policy 31-103 – Registration Requirements [PDF]

June 20, 2007

IIAC Letter to Finance on the Definition of Eligible Financial Contract [PDF]
June 8, 2007

IIAC Comments to BSC and AMF Regarding the Proposed National Instrument 11-102 and Companion Policy 11-102CP Passport System [PDF]
May 25, 2007

IIAC Comments on Proposed NI 11-102 and CP 102CP [PDF]
May 25, 2007

IIAC Comments to IOSCO on Market Intermediary Management of Conflicts That Arise in Securities Offerings [PDF]
May 18, 2007

IIAC Letter Requesting Changes to IDA Policy 11 [PDF]
May 7, 2007

IIAC Comments on Draft GST Legislation and Other Matters [PDF]
April 30, 2007

IIAC Letter to the OSC to Request to Address Inequitable Competitive Effect (Revised) [PDF]
April 23, 2007

IIAC Letter to DOF Regarding RRIF Transfers [PDF]
April 23, 2007

IIAC Letter to DoF Regarding the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations [PDF]
April 12, 2007

IIAC Response Letter to CSAs Regarding NI 41-101 [PDF]
March 28, 2007

IIAC Letter to the OSC Regarding the Cost-Benefit Analysis for Client-Relationship Model (CRM) [PDF]
March 27, 2007

Ian Russell (IIAC) Presentation to Toronto Board of Trade – Small Is Beautiful [PDF]
March 7, 2007

IIAC Letter to DoF on Request for Amendment to Income Tax Regulations Related to Mark to Market Rules [PDF]
February 14, 2007

IIAC Letter to BCSC Regarding the Recognition of egX Canada as an Exchange [PDF]
February 13, 2007

IIAC Letter to the IDA Regarding the By-Laws 19 and 20 Reform Project [PDF]
February 8, 2007

IIAC Remarks on Proposed Regulations (REG-140206-06) [PDF]
February 6, 2007

IIAC Letter to Minister Flaherty on Advantage Canada [PDF]
January 23, 2007

IIAC Letter to the OSC Regarding the IDA Incorporation By-Law [PDF]
January 22, 2007

IIAC Data Elements Initiative [PDF]
January 18, 2007

IIAC Letter to the OSC Regarding the Incorporation of Individuals [PDF]
December 20, 2006

2006-12-05E IIAC Letter to the IRS Regarding theCanadian KYC Attachment [PDF]
December 5, 2006

IIAC Letter to IDA Regarding the Rules of the Client Relationship Model (CRM)[PDF]
November 22, 2006

IIAC Response to MRS Regarding RS Market Integrity Notice 2006-20 – Provisions Respecting Competitive Marketplaces [PDF]
November 13, 2006

IIAC Comments to the OSC on Proposed National Instrument 23-102 [PDF]
October 30, 2006

IIAC Comments to Finance Regarding the Need to Prioritize the Updating od Securities Transfer and Related Laws [PDF]
October 18, 2006

IIAC Comments to the CSA on Debt-Markets Transparency, NIs 21-101 and 23-101 and Companion Policies 21-101CP and 23-101CP [PDF]
October 12, 2006

IIAC Comments to DOF Regarding the Eliminating of Double Taxation of Large Corporate Dividends[PDF]
September 28, 2006

IIAC Letter to Finance Regarding Proposed Legislation to Eliminate the Double Taxation of Large Corporate Dividends [PDF]
September 15, 2006

IIAC Letter to the OSC Regarding the Proposed Amendment to IDA By-Law 39[PDF]
August 24, 2006

IIAC Letter to the MEDT on the Financial Sector Strategy [PDF]
August 10, 2006

Joint Industry Association Submission to DoF Regarding Reporting of Canada Revenue Agency (CRA) Information Slips and Reporting to CDS[PDF]
July 25, 2006

IIAC Letter To Industry Canada on the Need to Amend the BIA and CCAA [PDF]
June 26, 2006

IDA Response to CSA National Instrument 24-101 – Institutional Trade Matching and Settlement [PDF]
May 9, 2006

IDA 2006 Federal Pre-Budget Recommendations [PDF]
April 19, 2006

IIAC Letter to the CRTC Regarding Do Not Call Framework [PDF]
March 27, 2006

IDA Submission to the National Assembly of Quebec Regarding Protection of Investors in Quebec [PDF]
January 2006

IDA Submission to the Minister of Finance Regarding Flow-Through Entities [PDF]
November 28, 2005

IDA Letter to Industry Canada Regarding RRSP Regulations Bill C-55 [PDF]
September 20, 2005

IDA Comments on the Draft Legislation Regarding the Deductibility of Interest and Other Expenses [PDF]
February 2, 2004

IDA Letter to the Ministry of Finance Regarding Transfers of RRIF Plans and the Requirement to Pay Out the Annual Minimum Amount [PDF]
January 10, 2003