Response to BCSC’s proposed fee changes
This submission advocates for a more transparent, predictable, and disciplined approach to regulatory fee-setting, helping firms better manage costs while continuing to support investors and capital markets.
SIMA Submission – BCSC – Consultation on Proposed Fee Changes
Recipients
- British Columbia Securities Commission (BCSC)
Industry segments this resource supports
- Assets management
- Capital markets
Summary
SIMA submitted comments to the British Columbia Securities Commission in response to its consultation on proposed fee changes. While supporting the BCSC’s periodic review of fees and its efforts to ensure long-term regulatory sustainability, SIMA raised concerns about the cumulative impact of regulatory fee increases across Canada. The submission recommends that fee-setting be guided by transparency in cost recovery, predictability through multi-year frameworks, and discipline in the use of existing surpluses before implementing fee increases.
Why this matters: This submission advocates for a more transparent, predictable, and disciplined approach to regulatory fee-setting, helping firms better manage costs while continuing to support investors and capital markets.
Key takeaways
- SIMA supports the BCSC’s review of its fee structure and recognizes the importance of maintaining the regulator’s long-term sustainability.
- The association is concerned about the growing burden of cumulative regulatory cost increases facing firms across multiple jurisdictions.
- SIMA recommends adopting multi-year fee frameworks supported by accurate cost forecasting to improve certainty and business planning.
- The submission calls for greater transparency regarding cost-recovery calculations, operational efficiencies, and the management of regulatory surpluses.
- SIMA questions the rationale for increasing exempt distribution report filing fees, noting that these filings are highly standardized and may benefit from automation and technology-driven efficiencies.
- The association requests clarification on how the projected increase in annual fee revenue would be allocated among registrants, issuers, and filing types.
- SIMA supports greater consistency and coordination of regulatory fees across Canadian jurisdictions to reduce complexity and costs for firms operating nationally.
