CSA Extends CRM2 July 15, 2015 Reporting Deadline by 6 months

The CSA letter published on January 28, 2015 said that CRM2 amendments scheduled to come in to force on July 15, 2015 have been extended to December 31, 2015 in response to an IIAC letter managing director Barbara Amsden sent to the CSA on December 20, 2014. This gives dealers an additional 6 months to program for the new statement disclosure requirements including position cost information and market values using prescribed methodology.

Aligning disclosures to the calendar year makes sense because that’s how financial institutions report and how investors plan. It ensures investors have consistent, relevant information when they need it most; at RRSP season when they file taxes and are focused on financial planning, as opposed to July when they take holidays.

The July 15, 2016 CRM2 annual performance report and fee report requirements deadline remain unchanged. However, an important change is that firms that report for the calendar year 2016 can now use an inception date of January 1, 2016 and will not be required to include comparative data from 2015. The definition of “book cost” will not change; registered firms that wish to provide tax-adjusted cost information to their clients can do so as supplementary information.

The regulators are often criticized for being out of touch and unsympathetic to industry’s concerns, but here’s an instance where they’ve recognized an oversight and taken prompt steps to meet industry’s needs. It underscores the importance of our industry having a unified voice to address concerns to the regulators.