The foundation of good public policy is simple: identify the problem, measure it, and design a solution proportionate to the risk.

Canadian securities regulators are proposing to ‘clarify’ reporting requirements for single-issuer ETFs, American Depositary Receipts, Canadian Depositary Receipts and structured notes by alleviating an available exemption to address ‘a potential reporting gap’.

No evidence of the gap has been provided.

Regulators should show the public the scale and nature of the problem. If the evidence supports reform, the public can engage constructively on targeted solutions. If the evidence is absent, the proposal should be reconsidered.

Healthy, competitive markets need clear, proportionate rules.

See CFFiM analysis here.