The IIAC submitted comments on the CSA Proposed National Systems Renewal Program Rule and Related Amendments and System Fees for SEDAR and the National Registration Database
(NRD).
The IIAC agrees that the redevelopment of the existing outdated and unwieldy systems into an integrated framework is an important step in ensuring the regulatory infrastructure employs appropriate technology and system design to meet the industry’s current and future requirements. Although it may be practical to deliver the four components of the Renewal Program in separate phases, the IIAC expressed disappointment in the extended timeline for delivery and believes it would be appropriate to prioritize the NRD. The NRD has design and operational flaws that require a significant amount of manual entry, often of the same information, and results in a disproportionate amount of time spent entering, re-entering and searching for data that should be easily accessible. If the proposed timeline stands, the IIAC recommends a number of adjustments to the existing system to significantly improve its functionality until the Renewed System is fully implemented. You can click here
to read our comment letter.
In respect of the Proposed Fee Structure, the IIAC believes it provides a coherent, simplified, and fair means for charging for access and use of the system. The flat fee design, payable only to the filer’s principle regulator, significantly simplifies the process and reduces resources required by users to manage administrative tasks. Click here
to read our comment letter.
For more information, please contact Susan Copland.