CSA proposal to modernize continuous-disclosure requirements for investment funds

Submission – CSA notice and request for comments – Proposed amendments and changes to modernize the continuous-disclosure regime for investment funds

Recipients

• The Canadian Securities Administrators (CSA) 

Industry segments this resource supports

• Assets management

Summary

We submitted recommendations to the CSA about its proposal to modernize continuous-disclosure requirements for investment funds. While we support the CSA’s goal of improving disclosure quality and reducing regulatory burden, we raise concerns that some proposed requirements may reduce clarity, increase liability risk, or duplicate existing obligations. We propose targeted changes to ensure disclosures remain practical, relevant, and beneficial for investors. 

Why this matters: The proposed changes to continuous‑disclosure requirements will directly affect how investors receive, understand, and use information about their investment funds.

Key takeaways

• We support the CSA’s initiative to modernize continuous-disclosure rules but warn‑ that several proposals may unintentionally reduce clarity or increase regulatory burden. 
• We recommend providing two years of fund-expense-ratio data without requiring a written summary to make cost comparisons easier for investors. 
• We urge the inclusion of performance data for all fund classes or series so investors can find information relevant to their specific holdings. 
• We recommend retaining existing MRFP requirements for “results of operations” and “recent developments” rather than introducing new assessments that could increase liability risk. 
• We advise aligning ESG disclosure expectations with CSA Staff Notice 81‑334 instead of creating new, inconsistent requirements. 
• The proposed liquidity profile section is considered unnecessary for mutual fund and ETF investors and should be removed. 
• We suggest integrating statistics into the performance section and retaining existing requirements for discussing material changes in portfolio assets to avoid duplicative or less meaningful standalone sections. 
• We recommend eliminating standalone risk profiles and borrowing/leverage sections and instead disclosing material changes within a general section. 
• We also propose removing leverage disclosure requirements from financial statements to reduce duplication and regulatory burden. 

Overall, the recommendations aim to improve clarity, relevance, and usability of disclosure materials to support informed investor decision-making.