The IIAC’s response to the Proposed Amendments to NI 44-102 Shelf Distributions and Change to Companion Policy 44-102CP Shelf Distribution relating to At-the-Market Distributions (ATM) affirms our support of the CSA’s initiative to replace the burdensome and inefficient exemptive relief process for conducting ATM distributions. By aligning the Canadian framework for ATM distributions with the U.S. ATM model, the Proposals will facilitate efficient usage of this means of financing in Canada.
To optimize the Proposals, changes to the Canadian ATM framework are needed to provide similar efficiencies as the U.S. framework. These changes include the removal of the prospectus specific right for rescission or damages, the removal of translation requirements, and the specific designations of ATM Exchanges, which would limit the marketplaces upon which the offerings can be conducted.
For more information, please contact Susan Copland.