NIN 97/16 - Report of the CSA Investment Funds Implementation Group [NIN - Rescinded]

Published Date:	1997-05-23
Effective Date:	1997-05-20

At the Spring meeting of the Canadian Securities Administrators (CSA) held in Toronto on April 16-18, 1997, the CSA approved the Report of the CSA Investment Funds Implementation Group (the Implementation Group).

Morley Carscallen, Vice-Chair of the Ontario Securities Commission, acts as chair of the Implementation Group. Other members of the Implementation Group are:

• Douglas Hyndman, Chair, British Columbia Securities Commission
• Marcel de la Gorgendiere, Q.C., Chair, Saskatchewan Securities Commission
• Guy Lemoine, Vice-Chair, Quebec Securities Commission
• Robert MacLellan, Chair, Nova Scotia Securities Commission.

Jacynthe Hotte, a former Vice-Chair of the Quebec Securities Commission, was a member of the Implementation Group prior to her leaving the Commission. Mr. Lemoine replaced Ms. Hotte on the Implementation Group.

The Report of the Implementation Group, as endorsed by the CSA follows.

Background to the Report

In early 1994, former OSC Chairman Ed Waitzer requested Glorianne Stromberg, a Commissioner with the Ontario Securities Commission, to review the existing investment fund regulation and recommend changes. Commissioner Stromberg tabled her report "Regulatory Strategies for the Mid-'90s: Recommendations for Regulating Investment Funds in Canada" with the CSA in January, 1995.

The OSC, supported by the CSA, responded to the Stromberg Report by asking a group of industry leaders and regulatory representatives to discuss and provide their views on the various recommendations made in the report. The Investment Funds Steering Group began work in the summer of 1995 and consulted widely with other industry representatives through the formation of five working committees. The Investment Funds Steering Group submitted its report "The Stromberg Report: An Industry Perspective" to the CSA in November 1996.

The CSA decided in late 1996 to constitute a high-level CSA committee to consider how the CSA should tackle implementation of the various recommendations made by Commissioner Stromberg, as commented on by the Steering Group. The Implementation Group was organized as a result of that decision.

Overview of the Report

The Implementation Group reviewed all the recommendations made by Commissioner Stromberg, as commented on by the Steering Group. In the Report, the Implementation Group identifies discrete subject areas resulting from the recommendations and outlines for each such subject area:

• a priority for implementation;
• a proposed CSA action;
• the degree to which the CSA is already implementing the recommended action;
• suggestions for implementation and staffing to be undertaken by the CSA.

The Report is a blueprint for change in the regulation of the mutual fund industry. It also underscores the fact that significant progress has already been achieved on a number of the recommendations that the CSA has identified as high priorities.

Implementation

The members of the Implementation Group will continue their work to ensure that the applicable projects identified in the Report are commenced, and once commenced, are carried out in as timely manner as possible and with input from experts and other industry groups as deemed necessary. The Implementation Group will also ensure that the various projects are proceeded with in an orderly and integrated manner.

The first priority of the Implementation Group will be to move as quickly as possible to form staff groups to be responsible for completion of, at a minimum, the high priority projects indicated in the Report. The Implementation Group will also consider which of the medium priority projects could be undertaken at the same time as the high priority projects, having regard to the availability of staff resources.

The CSA recognizes that not all projects identified in the Report can be undertaken simultaneously; of necessity, certain projects must await additional staff resources or the completion of other regulatory or industry initiatives.

Any new rules and policies that result from any initiative undertaken and completed by the CSA will be subject to the rule-making procedure, including the public comment process and ministerial approval, required by applicable securities legislation.

Implementation Group Contact

Members of the Implementation Group may be contacted at:

Douglas Hyndman, Chair
British Columbia Securities Commission
1100-865 Hornby Street
Vancouver, British Columbia
V6Z 2H4
(604) 660-4888; fax- (604) 660-2688

Marcel de la Gorgendiere, Q.C., Chair
Saskatchewan Securities Commission
800, 1920 Broad Street
Regina, Saskatchewan
S4P 3V7
(306) 787-5645; fax - (306) 787-5899

Morley Carscallen, Vice-Chair
Ontario Securities Commission
800, 20 Queen Street West
Toronto, Ontario
M5H 3S8
(416) 593-8081; fax - (416) 593- 8241

Guy Lemoine, Vice-Chair
Commission des valeurs mobilieres du Quebec
800, square Victoria, 17th floor
C.P. 246, Tour de la Bourse
Montreal, Quebec
H4Z 1G3
(514) 873-5326; fax - (514) 873-6155

Robert MacLellan, Chair
Nova Scotia Securities Commission
P.O. Box 458
Halifax, Nova Scotia
B3J 2P8
(902) 424-7768; fax - (902) 424-4625

Questions may also be referred to:

Rebecca Cowdery, Special Counsel, Market Operations
Ontario Securities Commission
(416) 593-8129; fax - (416) 593-8244.

DATED at Vancouver, British Columbia, on May 20, 1997

Douglas M. Hyndman
Chair

SR=Stromberg Report
SG=Steering Group
QCC=Quebec Consultative Committee
IFIC=The Investment Funds Institute of Canada
IDA=Investment Dealers Association of Canada
CSA=Canadian Securities Administrators
NP39=National Policy Statement No. 39 - Mutual Funds

STROMBERG RECOMMENDATION	CSA PRIORITY	PROPOSED CSA ACTION	IMPLEMENTATION AND STAFFING	COMMENTS
Centralized regulatory system for the regulation of mutual funds [SR - 4.01 -4.12 - central commission to regulate funds] [SG - not dealt with - see p. 6 re need for more CSA coordination]	High - coordinated prospectus review ; Medium all other CSA action	CSA should work to achieve better coordinated regulation of investment funds; work towards eliminating inconsistencies in procedural matters and legislation and regulation Not a priority for the CSA to consider implementing or establishing a central commission (real or virtual) to regulate mutual funds	Designate CSA staff group to identify major inconsistencies and recommend suggested changes CSA Mutual Fund Committee to continue to develop a "coordinated [mutual reliance] prospectus review system" for mutual funds	CSA Mutual Fund Committee has developed a coordinated [mutual reliance] prospectus review system that was approved by the CSA Chairs at the Spring 1997 CSA meeting - a description of the review system will be published for comment once completed
National SRO to regulate activities of all securities dealers, including investment funds [SR - 9.02 and 9.03] [SG - pps 9-13 - agreement in principle - discussion how to implement this recommendation] [QCC - p. 59 - consider governmental proposals on market intermediaries; favours coordination mechanisms between SROs]	High	CSA long term objective to get all dealers into an SRO - ideally one SRO, but with a recognition of the eventuality of a new SRO in Quebec for industry participants who qualify as market intermediaries CSA encouragement to industry to develop SRO structure - whether new SRO(s) or add-on to the IDA - and to develop appropriate categories of membership	High level CSA involvement to facilitate discussions among industry groups, inclusive of the IDA and IFIC and to ensure discussions continue	OSC has decided to proceed with a rule requiring all securities dealers and mutual fund dealers to become members of an SRO recognized by the Commission. The OSC is targeting March 1, 1998 as the effective date for the rule and as the date that a fully staffed SRO would be in place. CSA recognizes that it would be optimal that this rule be a national rule and the SRO be a national SRO.
Disclosure System - Primary and Continuous [SR - 17] [SG - disagreement with SR proposals for the prospectus system - agreement with certain recommendations - pps. 31-35]	High, partially underway	CSA Mutual Fund Committee should continue with development of the prospectus disclosure system and the changes to the continuous disclosure regime applicable to mutual funds described in the Concept Proposal released for comment on January 31, 1997 CSA Mutual Fund Committee should review and consider all recommendations discussed in the SR, as commented on by the SG and the QCC, in the area of disclosure and recommend action to be taken in response	CSA Mutual Fund Committee, with liaison with the CICA study group considering financial reporting for investment funds and with input from IFIC	"Associates" draft of the CICA research report "Financial Reporting by Investment Funds" has been released to a limited group for comments On February 27, 1997, SEC released proposals for changes to mutual fund disclosure rules in the United States CSA Mutual Fund Committee to take into account both the CICA proposals and the SEC proposals in developing their recommendations Proposed National Instrument to replace NP39 to contain rule that imposes "timely disclosure" requirements where a "significant change" in the operations of a mutual fund occurs - deals with the deficiencies noted in the SR with definitions of material change contained in securities legislation in mutual fund context
Governance of Investment Funds [SR - 14.01, 18.04] [SG - no need for independent board at manager level, so long as independent board at fund level - to be the board for a fund family - pps. 50-52] [QCC - p. 42 - agreement with board for fund family - disagreement with independent members majority]	High	CSA should develop rules to regulate the governance of investment funds CSA should commence work on this recommendation in priority to those recommendations that depend upon the independent governance mechanism being resolved - for example, registration of fund managers and conflicts of interest	Designated CSA staff to form group to review this area and recommend appropriate rules; group should seek outside legal expertise, where necessary and should consult with IFIC and fund manager representatives	IFIC has formed a committee to formulate best practices guidelines for fund governance - CSA group to liaise with this committee and to monitor industry developments
Common regulatory regime for all collective money management schemes [SR - 7 and 8.04] [SG - not dealt with in detail, other than generally endorsed - see p.6 and p. 9 references] [QCC - see discussion on pps. 51-58 re segregated funds, labour sponsored investment funds, wrap accounts and group RRSPs]	Medium	CSA should approach the insurance regulators to better understand regime applicable to segregated funds and to determine how to ensure consistent regulation of mutual funds and segregated funds CSA should monitor the experience in Quebec as changes to the law on market intermediaries, including the self regulatory regime, unfolds CSA should work towards a better understanding of "wrap accounts" and their marketing in Canada and how they are regulated in the United States CSA should work towards a better understanding of developments in the "group RRSP" and money purchase plan field and the use of mutual funds in connection with these arrangements	Designated CSA staff to request assistance from IFIC and other industry representatives in better understanding "wrap" account market and the "group" tax and pension plan area; staff to also review the regulation in this area in the United States	Not recommended at this time to lobby for legislative changes to bring segregated funds or other insurance regulated products within the oversight of the CSA senior OSC Commission and staff representatives have had preliminary discussions with the Ontario insurance regulators to discuss consistent regulation and other regulatory issues
Standards for Distributors of Investment Funds [SR - 12 and 9.03] [SG - general agreement with recommendations and commentary on specific recommendations - pps. 17-20] [QCC - pps. 30-35 - general agreement, certain recommendations differ; eventual extension of the concept of multidisciplinary firms for market intermediaries to be taken into account]	Medium - will become high priority as SRO discussions develop	CSA to review SR recommendations, as commented on by the SG and the QCC, together with the submission of the Independent Mutual Fund Dealer Group from IFIC (July 1996) and develop appropriate regulatory regime for mutual fund dealers - proposal could be adopted either by SRO for mutual fund dealer members or by CSA in the absence of an SRO that would regulate mutual fund dealers	CSA Capital Markets Committee to develop appropriate regime	Implementation Group noted, in particular, the regulatory problems concerning those representatives of mutual fund dealers who set themselves up as independent contractors via the use of corporations - this topic is deserving of particular attention by the CSA Capital Markets Committee Implementation of this CSA action is somewhat dependent on the anticipated development of a SRO to regulate mutual fund dealers
Standards for education, proficiency and training of industry participants [SR- 15.02] [SG - need for continuing education - pps 20-22]	Medium	CSA should convene, and work with, group referred to in SG report (p. 23) to develop a mandatory continuing education program for registrants CSA should work with industry educators to re-consider entry level course requirements for mutual fund dealers - and FI sales representatives	CSA staff to be designated to organize and proceed with this project	Implementation Group notes work being carried out in the United States by NASD regarding continuing education Implementation Group sees this project as a more long-term project - could be implemented in stages
Non Sales Related Business Practices [SR - 10.01, 10.02, 11.01, 11.02, 11.03, 11.04 and 13.04] [SG - discussion on recommendations contained on pps. 24/25]	Medium	CSA should consider whether CSA rules or business practice guidelines necessary to regulate topics indicated	CSA Capital Markets Committee to review issues and to seek industry assistance/input from IFIC and the IDA
Registration of Investment Fund Managers and Service Providers [SR - 14.01 re registration of fund managers and 14.03 re registration of service providers] [SG - agreement with registration for fund managers - pps. 25-30 - discussion on applicable conditions of registration -do not agree with registration for service providers] [QCC - p. 40 - discussion of concerns with minimum capital requirement proposed in the SR]	Medium - to be completed after fund governance project completed	Once the issue of governance of mutual funds is resolved, CSA should consider the registration of managers and the appropriate conditions of registration	Designated CSA staff group to consider fund manager registration and the appropriate conditions of registration and to seek industry input from IFIC and fund managers Designated CSA group to be the same group as considers the fund governance and conflicts of interest issues	Topic includes discussion on the seed capital required to be injected by managers into funds - presently dealt with by section 3 of NP39 and the National Instrument to replace NP39 does not propose to change regime at the present time
Conflicts of Interest [SR - 19.03 - 19.16, 20.01 and 20.02] [SG - desire for more regulatory reliance on independent fund boards to review related party transactions - pps. 53-55]	Medium, dependent on fund governance project	CSA should review the SR recommendations with a view to determining whether any alternatives to strict prohibition exist or whether any changes to the conflicts regime applicable to mutual funds should be made OSC, and other jurisdictions with similar regimes, should review the deficiencies noted with the current conflicts of interest regime provided for in the OSA - as discussed in the OSC staff paper entitled "Conflicts of Interest in the Management of Mutual Funds"	Designated CSA staff group to review area once governance project largely completed Work on identifying legislative changes to take account of the deficiencies noted in the OSC staff report could be proceeded with by an independent staff group, however, no changes should be proposed until the work of the above-noted designated CSA staff group is completed	Project is contingent on the development of independent fund governance mechanism and therefore cannot be completed before fund governance is worked out
Code of Ethics for Fund Managers [SR - 14.04] [SG - agreement with concept of code of ethics - pps. 56/57]	Medium - to be carried out in conjunction with review of registration of fund managers	CSA should follow the work of IFIC in this area and should consider whether rules are necessary after reviewing IFIC’s final work; CSA should review the provisions prohibiting "front running" contained in securities legislation, and suggest legislative changes to resolve any problems	Designated CSA staff group reviewing fund governance and registration issues to be in contact with IFIC regarding its proposals for a code of ethics for fund managers and to be charged with this project in conjunction with its work on the registration of fund managers
Regulation of Financial Planners [SR - 15.03] [SG - present state of no oversight of financial planning activities is not desirable - p. 14 - endorsement of Financial Planners Standards Council] [QCC - p. 52 - harmonize oversight of financial planning activities conducted by dealer registrants and other professionals]	Medium	CSA should establish liaison with Financial Planners Standards Council of Canada CSA should monitor British Columbia proposals to develop regulations for dealers/registrants who carry out financial planning activity, with a view to adopting national scheme in this regard CSA should monitor Quebec and Saskatchewan proposals/developments to determine if national regulation of financial planning activity (more generally) could be achieved	Designate CSA staff person(s) as FPSCC liaison and as CSA staff responsible for keeping abreast of industry and regulatory developments generally in this area; keep the other CSA informed, as necessary	Implementation Group noted a regulatory concern in this area is the extent of the jurisdiction of the CSA to regulate financial planning activity that is not conducted by dealer-registrants - financial planning is not necessarily trading or advising in securities and therefore may fall outside the jurisdiction of the CSA
Calculation and Use of Performance Information; Standards for Advertising and Sales Communications [SR - 24] [SG - no additional rules/standards necessary re calculation of performance information - outlines various matters regarding the use of performance information and suggests standards for advertising and sales communications - pps. 35-46]	Medium	CSA should establish liaison with CICA study group, with a view to determining whether this group considered the problems identified in the SR concerning the calculation of performance information - confirm whether or not the conclusion reached by the SG is correct CSA should develop additional rules/policies, as needed to respond to the SR recommendations in the area of use of performance information and sales communications standards, as commented on by the SG CSA hould establish a more formal link between CSA staff and the IFIC sales communications committee	CSA Mutual Fund Committee to meet with the CICA study group regarding calculation of performance information and report back to the CSA Chairs CSA Mutual Fund Committee to develop additional rules/policies regarding the use of performance information and other sales communication standards, as necessary, to be part of National Instrument to replace NP39; rules to be published in the second round publication of the National Instrument for comment Ontario staff to work to establish a liaison and link with the IFIC sales communications committee; keep other CSA informed, as required	Implementation Group notes that the National Instrument to replace NP39 contains proposed rules that implement certain of the SG recommendations for simplified advertising disclaimers and is more clearly prohibiting the use of performance information in advertising "young funds"
Categorization of Investment Funds [SR - 24.03] [SG - suggests categorizations and proposed use for categorizations - pps. 38-40 and Appendix A]	Medium	CSA should request IFIC to review the categorization of Canadian mutual funds and to suggest appropriate categories and how the regulatory regime might recognize categories of mutual funds	Designated CSA staff person to act as liaison with IFIC in this regard	Implementation Group decided to treat this topic as a discrete topic, although it forms part of the SR recommendations relating to use of performance information
Investor Education [SR - 15.04] [SG - agreement with general philosophy, with discussion of role of industry participants in educating investors - pps. 46-49]	Medium	CSA should consider what role it should play in providing investor education and determine what additional rules are necessary in order to regulate the activities of industry participants in providing educational programs, materials etc. to investors CSA should pay particular attention to the activities of professional investor educators and the role of industry participants in sponsoring investor programs - this review extends beyond the mutual fund industry	CSA Investor Education Committee to undertake review of this area	The National Instrument to replace NP39 clarifies that the rules regulating sales communications apply to all communications (oral and written) made as part of sales process - for example, communications at investor conferences cannot be misleading
Soft Dollars [SR - 21 - discussion as to the problems with soft dollars] [SG - no need for ban - regulation to ensure commission dollars used only for the benefit of the fund]	Medium - same timing as other reformula-tion projects	CSA should proceed with a national instrument to regulate soft dollars - based on draft National Policy Statement No. 52 [as developed in 1992], with amendments to reflect suggestions of SR, SG and the "framework " for the regulation of soft dollars prepared by an industry group and delivered to the CSA in 1995	CSA staff working on reformulation of mutual fund policies to proceed with this project - to be a reformulation on a national basis of OSC Policy Statement No. 1.9	Implementation Group notes that Quebec raised certain impediments to the implementation of proposed NP52 in 1992 - these impediments must be identified and dealt with
Fund - of - Funds [SR - 22] [SG - beyond scope of SG to conduct the further research recommended in SR - p. 56] [QCC - p. 45-48 - current restrictions should be relaxed]	Medium	CSA to compile research paper that consolidates all research conducted to date, and updates such research where necessary and discusses regulation of fund-of-funds in other jurisdictions, particularly the US, and then develop appropriate rules	Designate a CSA staff person to prepare the research paper and recommend appropriate rules, with liaison and input, as necessary from IFIC	Implementation Group notes the recommendation of the SG that the CSA should deal with fund of funds and accordingly, notwithstanding the "medium" priority given to the proposed CSA action, will endeavour to have this matter proceeded with as expeditiously as possible, and once commenced, will set a shorter-term deadline for completion of this project finalization of this project is dependent on the completion of the fund governance project
Fund Investment Strategies [SR - 25.03, 25.04, 25.05 and 25.06] [SG - commentary on recommendations - pps. 57-59]	Medium for projects noted, low for others	CSA should review securities lending by mutual funds, together with a review of the use of repurchase agreements by mutual funds No action to be taken by CSA at present with respect to other recommendations	CSA Mutual Fund Committee to review area and make recommendations, with liaison with IFIC and with the Commodity Futures Advisory Board	CSA Mutual Fund Committee requested, and has received, a submission from IFIC regarding the regulation of the use of repurchase agreements by mutual funds and has reviewed past submissions made regarding securities lending
Order Processing and Settlement System [SR - 13.02] [SG - suggest MFCS be recognized as a clearing system pps. 63-64]	Medium	CSA to become familiar with Mutual Fund Clearing and Settlement Services Inc., with a view to recognition of system as a clearing system	Designate CSA staff person to become familiar with, and advise CSA Chairs on MFCS
Investment funds that are reporting issuers not presently in distribution to be subject to same rules as funds in distribution [SR - 18.03] [SG - not dealt with]	Underway - no further action necessary	National Instrument to replace NP39 will clarify that the mutual fund rules continue to apply to a mutual fund out of distribution (so long as the fund continued a reporting issuer and at some point in its history had offered securities by way of prospectus) No further action necessary to deal with this recommendation	CSA staff reformulating NP39
Use of technology in distributing investment funds [SR - 6] [SG - general agreement - pp.s 15-16]	Underway - no further action necessary	Proposed National Instrument 33-104 - Distribution Networks deals with the regulation of the use of toll-free lines and trades through electronic systems - this National Instrument reverses the current prohibition in the Principles of Regulation for trades through electronic means CSA should monitor technological developments in the distribution of all securities to determine appropriate regulation	Proposed National Instrument 33-104 close to publication for comment CSA staff group (BC, Alberta, Sask, Ontario, Quebec staff) presently reviewing the regulatory issues surrounding the use of the Internet and other electronic communication devices by issuers (not just mutual fund issuers) and dealer registrants to (i) satisfy document delivery requirements and (ii) conduct trades in securities
Sale of Investment Funds by Financial Institutions [SR - 8.02 and 8.03] [SG - general agreement - p. 14/15]	Underway - no further action necessary	Proposed National Instruments 33-102 - Networking Arrangements Governed by Securities Legislation and 33-103 - Distribution of Securities at Financial Institutions deals with the issues identified in the SR No further action necessary by CSA concerning this recommendation	Proposed National Instruments close to publication for comment
Sales Incentives and Practices [SR - 10] [SG - endorsement of IFIC Code and OSC decision to make a rule based on IFIC Code - pps. 12/13]	Underway - no further action necessary	Proposed National Instrument to regulate Mutual Fund Sales Practices - "nationalization" of proposed OSC Rule 81-503 Sales Practices published for comment August 30, 1996, with amendments to reflect comments with which the CSA agrees No further action required by the CSA with respect to the SR recommendations	Proposed National Instrument - Mutual Fund Sales Practices scheduled to be published for comment by summer of 1997 [subject to CSA approval] Mutual fund reformulation group working on proposed national instrument
Fundamental Changes to Investment Funds and Investor Rights [SR - 27.09 and related discussion in 17.04] [SG - discussion on p. 61]	Underway - no further action necessary	No further action to be taken by CSA, other than to seek comment on issues in the Notice to accompany the publication of the National Instrument to replace NP39	CSA staff involved in reformulating NP39
Miscellaneous Management Matters [SR - 27.04, 27.05, 27.06, 27.07, 27.08] [SG - commentary on recommendations - p. 61/62]	Underway - no further action necessary	No further action to be taken by CSA at this time, other than to propose T plus 3 settlement via the reformulation of NP39 and to monitor IFIC’s development of guidelines for transfers between registered tax plans and to request IFIC’s assistance in devising appropriate error correction procedures	CSA staff involved in reformulating NP39 to proceed with this project (T plus 3 to be proposed via first publication of the National Instrument to replace NP39, other rules, once developed, to be proposed in a second publication for comment of the National Instrument to replace NP39)	IFIC Committee is looking at best practices guidelines for transfers between registered tax plans
Joint regulatory coordination group to coordinate regulation amongst groups to ensure no regulatory gaps [SR - 5.01 - and related 8.05] [SG - not dealt with - other than endorsed as a "good idea" - p. 9]	Low	Not a priority for CSA at present and in any event a review of "regulatory gaps" between the various regulators should not be restricted to mutual fund regulation
Role of IFIC [SR - 16 - IFIC to continue as trade association - not SRO for industry] [SG - agreement in principle - p. 11]	Low	IFIC to resolve its role vis a vis the CSA recommendation that all dealers be members of an SRO(s) No further action required by CSA, at this time
Regulatory regime governing investment funds [SR - 18.01 and 18.02] [SG - not dealt with]	Low	Not a priority for CSA at present - having regard to the need for legislative will at either the federal or provincial level to adopt an investment funds statute		Implementation Group recognizes the attractiveness of this recommendation, in theory; that is, a statute could easily provide for many of the matters the CSA must mandate by rule
Withdrawal and Rescission rights applicable to investment fund investors [SR - 17.05] [SG - not dealt with]	Low	Not a priority for the CSA at present		Implementation Group noted that IFIC has raised this matter as an issue from time to time and agreed that the CSA might wish to look at this area if IFIC indicated (i) the problems and how significant they were and (ii) why the CSA should deal with these problems for mutual fund purchases only (are these problems unique to mutual funds) Legislative changes would be necessary to amend the legislation in each jurisdiction if action were deemed necessary
Standards for Money Market Funds [SR - 23.01, 23.02 and 23.04] [SG - discussion on additional restrictions for money market funds - pps. 60-61	Low	CSA to await the final results of the CICA study group in this regard; study group considering the SR recommendations		Implementation Group notes that the proposed National Instrument to replace NP39 is making the most urgent changes to the definition of money market fund recommended in the SR and concurred in by the SG - that is - money market funds must only invest in securities maturing within 365 days and their portfolios must have a dollar weighted average term to maturity of 90 days
Custodianship of Assets [SR- 26.01, 26.02 and 26.03] [SG - p. 59]	Low	Not a priority for the CSA at present
Business Practice Standards for Mutual Fund Dealers [SR - 9.03] [SG - discussion 62/63]	Low	No CSA action necessary at this time - standards to be industry developed
Business Practice Standards for Mutual Fund Managers [SR - 14.01] [SG - discussion on pps. 62-63]	Low	No CSA action necessary at this time - standards to be industry developed
Money Laundering Detection [SR - 13.03] 9[SG - p. 64]	Low	No CSA action necessary at this time
Reduction of Potential for Incidents of Fraud [SR - 13.05] [SG - pp.s 64/65]	Low	No CSA action necessary at this time
Application of SARP standards [SR - 13.01 and 14.01] [SG - p. 65]	Low	No CSA action necessary at this time