AMF consultation on recalibrating regulatory fees
The AMF’s proposed fee changes will directly affect the cost structure and regulatory burden for firms operating in Quebec’s investment industry.
Submission – AMF – Recalibration of AMF fees
Recipients
- Autorité des marchés financiers (AMF)
Industry segments this resource supports
- Assets management
- Wealth management
Summary
This submission responds to the AMF’s consultation on recalibrating regulatory fees. We support reductions in fees for mutual fund dealers, investment dealers, and their representatives following the delegation of oversight to CIRO. However, we raise concerns about proposed fee increases for prospectus filings and Fund/ETF Facts, noting that the AMF has not provided sufficient data to justify the changes. The submission calls for greater transparency, improved consultation timing, and clearer rules for pre filing fees to ensure fairness and predictability for market participants.
Why this matters: The AMF’s proposed fee changes will directly affect the cost structure and regulatory burden for firms operating in Quebec’s investment industry.
Key takeaways
- SIMA supports the AMF’s decision to reduce fees for mutual fund dealers, investment dealers and their representatives as these reductions reflect the transfer of regulatory responsibilities to CIRO.
- SIMA urges other CSA members to adopt similar fee reductions to avoid duplication and promote fairness across jurisdictions.
- SIMA does not support the proposed fee increases for investment fund prospectus filings and Fund/ETF Facts due to insufficient supporting data.
- SIMA calls for more transparency and engagement from the AMF to better understand the rationale behind the proposed increases.
- SIMA supports the introduction of a $2,000 non refundable pre filing fee for draft document consultations but recommends exemptions for informal, non document based inquiries.
- SIMA highlights challenges with the timing of the consultation, noting that overlapping consultations during peak summer vacation periods limited member participation.
SIMA recommends improved publication practices to ensure meaningful industry engagement in future regulatory consultations
