The EMDA is a strong national voice for the exempt market. The EMDA monitors key issues affecting the exempt market, in particular the national rules of the Canadian securities regulatory authorities, including: 1) registration and compliance rules for EMDs under NI 31-103; and 2) exempt product rules for issuers and exempt client rules for issuers and dealers under NI 45-106.

The EMDA has made detailed written submissions to securities regulators and we meet regularly with senior representatives of the provincial securities commissions to advance the issues facing the exempt market professionals. We believe that a strong national voice for all exempt market professionals is critical to the success of our capital markets across Canada.

Recent EMDA comment letters and regulatory submissions include:

• EMDA comments on OSC Staff Consultation Paper 45-710 Considerations for New Capital Raising Prospectus Exemptions, submitted March 8, 2013
  

• EMDA responses to request for comments – Proposed Revocation of BC Instrument 32-513 Registration Exemption for Trades in Connection with Certain Prospectus-Exempt Distributions and BC Instrument 32-517 Exemption from Dealer Registration Requirement for Trades in Securities of Mortgage Investment Entities, submitted February 27, 2013

• EMDA comments on Canadian Securities Administrators Consultation Paper 33-403: The Standard of Conduct for Advisers and Dealers: Exploring the Appropriateness of Introducing a Statutory Best Interest Duty When Advice is Provided to Retail Clients, submitted February 22, 2013
  

• EMDA responses to the request for comments on Proposed Amendments to National Instrument 31-­‐103 published by the Canadian Securities Administrators (CSA) on November 15, 2012 in connection with the OBSI Proposal, submitted February 15, 2013
  

• EMDA comments on Accredited Investor and Minimum Amount review by CSA
  (CSA Staff Consultation Note 45-401 - Review of the Minimum Amount and Accredited Investor Exemptions - Public Consultations, submitted February 29, 2012) 
  
  
• EMDA expresses concern about the proposed securitized product rules which restrict EMDs and modify exempt market practices
  (Canadian Securities Administrators re. NI 41-103 and 51-106 - submitted August 31, 2011)
       
• EMDA expresses serious concerns about the exclusion of EMDs under the proposed direct market access rules
  (Canadian Securities Administrators re. NI 23-103 - submitted July 8, 2011)
  
  
• EMDA comments on proposed BC exempt distribution filing changes 
  (British Columbia Securities Commission re. NI 45-106 - submitted November 17, 2010)
   
  
• EMDA comments on "Year One' amendments to national registration regime (Canadian Securities Administrators re. NI 31-103 - submitted September 30, 2010)
  
  
• EMDA comments on the national registration regime and the final EMD registration category proposals
  (Canadian Securities Administrators re. NI 31-103 - submitted May 15, 2008)
  
  
• EMDA comments on the initial national registration regime proposals establishing the EMD category across Canada
  (Canadian Securities Administrators re. NI 31-103 - submitted June 18, 2007)