SIMA responds to AMF consultation on fee recalibration
September 19, 2025, Montreal, QC — The Securities and Investment Management Association (SIMA) has submitted its response to the Autorité des marchés financiers’ (AMF) consultation on the recalibration of regulatory fees.
SIMA welcomes the AMF’s reduction of fees for mutual fund dealers, investment dealers and their representatives, reflecting the delegation of powers to the Canadian Investment Regulatory Organization (CIRO). SIMA urges other Canadian Securities Administrators (CSA) members to follow this example to promote market fairness and avoid fee duplication.
However, SIMA is concerned about the proposed fee increases related to the filing of prospectuses and Fund/ETF Facts for investment funds. Due to a lack of detailed data supporting the increases, SIMA does not support them and calls for further transparency and engagement with the AMF to better understand and refine the proposals.
“We appreciate that the AMF has taken steps to align fees with delegated regulatory functions, which help strengthen fairness and competitiveness in Quebec’s investment industry,” said Marie Brault, Chair of the Board of Governors, SIMA Regional Council in Quebec. “At the same time, we encourage the AMF to provide detailed data on fee increases for investment funds to ensure transparency and fairness in cost recovery. We look forward to collaborating with the AMF and other CSA members to streamline and rationalize fee frameworks for the benefit of all market participants.”
SIMA also supports the introduction of a $2,000 non-refundable pre-filing fee for consultations involving draft documents that do not result in a formal filing, while recommending clear exemptions for informal, non-document-based inquiries.
In its submission, SIMA also highlights challenges in conducting a thorough member consultation due to the timing of the AMF’s simultaneous consultations during peak summer vacation months, and recommends improved publication practices for future regulatory amendments.
About SIMA
The Securities and Investment Management Association empowers Canada’s investment industry. The association is the leading voice for the securities and investment management industry, which oversees approximately $4 trillion in assets for over 20 million investors and the Canadian capital markets. Our members—including investment fund managers, investment and mutual fund dealers, capital markets participants, and professional service providers—are committed to creating a resilient, innovative investment sector that fuels long-term economic growth and creates opportunities for all Canadians.
For more information
Kia Rassekh
Director, Policy, Regional Director, Quebec
krassekh@sima-amvi.ca
514-985-7025
