TORONTO, March 27, 2026 /CNW/ - The Securities and Investment Management Association (SIMA) has responded to the Canadian Securities Administrators' (CSA) request for comments and feedback on proposed changes to the regulatory framework for liquidity risk management (LRM) of investment funds. The CSA is seeking to implement LRM requirements for investment funds in Canada to protect investors, promote fair, efficient and transparent markets, and reduce systemic risk.
SIMA supports the CSA's efforts to strengthen the LRM framework for investment funds and makes several recommendations to ensure its efficiency and effectiveness.
"We commend the CSA's commitment to safeguarding the interests of investors and minimizing the risk of liquidity crises," said Andy Mitchell, President and CEO, SIMA. "However, we urge the CSA to review practical considerations to establish an LRM framework that reduces regulatory burden and promotes operational efficiency."
SIMA's key recommendations
- Take into account the associated initial and ongoing operational and compliance costs.
- Exclude funds that are not reporting issuers and ETFs (including ETF series of mutual funds) from the proposed framework.
- Allow a minimum 12-month implementation period to ensure participants can design, test, and operationalize the framework.
- Eliminate proposed requirements for pre-trade liquidity assessments as the existing illiquid-asset limit and other elements of the framework already ensure that liquidity risks are effectively identified and managed.
- Allow firms to develop and implement internal policies, procedures, and stress-testing frequency that are most appropriate for an investment fund's particular liquidity risk profile.
- Separate liquidity classification from the National Instrument 81-102 illiquid-asset definition to reduce complexity and operational burden.
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.
SOURCE Securities and Investment Management Association

For more information: Christine Harminc, Director, Communications and Public Affairs, [email protected], 416-309-2313
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