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Bulletin #0853-P

For further information, please contact:

Stacey Shein
Senior Legal and Policy Counsel
For Distribution to Relevant Parties within your Firm

CSA Publication for Comment of Proposed Amendments to National Instrument 33-109 Registration Information and Changes to Companion Policy 33-109CP Registration Information

On February 4, 2021, the Canadian Securities Administrators (CSA) published for a 90-day public comment period, proposed amendments to National Instrument 33-109 Registration Information, including its related Forms, and changes to Companion Policy 33-109CP Registration Information. Related proposed amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and changes to Companion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations have also been issued for comment. Together these amendments and changes are referred to as the proposed revisions.

Proposed Revisions

The proposed revisions are intended to modernize registration information requirements, clarify outside activity reporting and update filing deadlines. Specifically, the revisions that would impact MFDA Members and Approved Persons include:

  • Outside Activities – The proposed framework for the reporting of outside activities is intended to narrow the outside activities that are reportable to regulators and provide clarity on the requirements. In this regard, the revisions include: referring to activities outside the sponsoring firm as “outside activities” (which is already provided for in MFDA Rules and staff guidance); establishing specified categories of outside activities that are reportable; and introducing a definition for positions of influence.
  • Reporting Deadlines – The revisions relating to reporting deadlines include extending the deadline from 10 days to 30 days for changes in information relating to: outside activities; an individual registrant’s address; a registered firm’s securities registration; and a registered firm’s conflicts of interest.
  • Registration Information Requirements – The revisions would clarify that the following information is included in the disclosures in Form 33-109F4 Registration of Individuals and Review of Permitted Individuals: non-compliance with securities laws, SRO rules or bylaws; criminal offences under foreign laws; and bankruptcy and other insolvency events regardless of how long ago they occurred.
  • Privacy and Consent – The revisions would clarify the privacy notice so that registrants can easily understand what personal information is being collected by the CSA and SROs, why it is being collected, and how and when it is being collected.
  • Information on Professional Titles – The revisions would require individual registrants to disclose the professional titles they use by including them on Forms such as Form 33-109F4.


The CSA Notice and Request for Comment re: the proposed revisions, a link to which is provided below, includes a list of 21 specific questions which stakeholders are asked to consider in their comment submissions. The comment deadline is May 5, 2021.

To view the proposed revisions, go to: