Greater transparency and efficiency in OSC fee changes

Submission – OSC – Proposed OSC Fee Rule Amendments

Recipients

Ontario Securities Commission (OSC)

Industry segments this resource supports

• Assets management
• Wealth management

Summary

SIMA submitted comments on the OSC’s proposed amendments to regulatory fee rules and companion policies. While supporting the OSC’s objectives of encouraging capital formation and economic growth, SIMA argues that fee-setting should be guided by greater transparency, accountability, predictability, and efficiency. The submission raises concerns about automatic CPI-based fee increases, proposed increases to certain filing fees, and the introduction of a new highest revenue-based fee tier. SIMA also recommends improvements to regulatory coordination, reporting transparency, and the participation fee model for investment dealers.

Why this matters: The submission advocates for a more transparent, predictable, and efficient regulatory fee framework that supports capital formation, economic growth, and competitiveness while helping firms manage rising regulatory costs.

Key takeaways

• SIMA supports the OSC’s goals of promoting capital formation and economic growth but believes fee changes should be considered within the broader context of increasing regulatory costs across Canada.
• SIMA opposes the proposed annual CPI-based fee escalator, arguing that participation fees already increase as industry revenues grow and that an additional automatic increase could create unnecessary regulatory burdens.
• The association questions proposed increases to exempt market report and Fund Facts filing fees and encourages the OSC to explore technology and AI-driven efficiencies before raising fees.
• SIMA recommends reducing fees for functions that have been delegated by the OSC to the Canadian Investment Regulatory Organization (CIRO), reflecting the regulator’s reduced responsibilities in those areas.
• The submission calls for stronger transparency and accountability through clearer reporting on costs, key performance indicators, reserves, surpluses, and fee-setting decisions.
• SIMA encourages the OSC and other Canadian Securities Administrators (CSA) members to adopt regulatory centres of expertise to reduce duplication, improve policy development, and support regulatory modernization.
• SIMA recommends revisiting the revenue-based participation fee model for investment dealers by allowing financing costs related to secured financing transactions to be deducted when calculating fees.

SIMA opposes the proposed highest revenue tier, stating that higher revenues do not necessarily correspond to greater regulatory risk or oversight requirements and could create a significant additional burden on major capital markets participants.