Proposed AMF regulatory fee increases in Quebec
Proposed AMF fee increases could raise costs for Quebec investors and reduce the competitiveness of the province’s investment industry.
Submission – Quebec Ministry of Finance – Regulation to Amend the Securities Regulation (AMF Fees)
Recipients
Ministère des Finances du Québec
Industry segments this resource supports
- Assets management
Summary
We urge the Ministère des finances du Québec to reject proposed increases to AMF regulatory fees for investment funds and instead adopt a transparent, predictable, multi year fee setting framework. We argue that the AMF already charges the highest investment fund fees in Canada and that further increases lack sufficient justification, risk burdening investors, and may hinder competitiveness, innovation, and market entry in Quebec. We recommend greater transparency, use of AMF budget surpluses before raising fees, and a clearer long term approach to regulatory cost management.
Why this matters: Proposed AMF fee increases could raise costs for Quebec investors and reduce the competitiveness of the province’s investment industry.
Key takeaways
- We oppose the proposed AMF fee increases due to insufficient substantiation and the already high level of fees charged in Quebec.
- We highlight that higher regulatory fees may ultimately be borne by investors and could limit firms’ ability to innovate, compete, and introduce new products.
- We note that the AMF has accumulated a significant budget surplus, which should be used before considering fee increases.
- We call for a defined multi year fee framework to improve predictability and support long term planning for investment and innovation.
- We emphasize the need for transparency in future fee amendment proposals and alignment across Canadian jurisdictions to ensure competitiveness.
