mining companies generate
no revenue in the early years—
Unfortunately, the current regulatory structure with 13
regulators in Canada is fragmented and inefficient, plagued by
onerous and costly regulatory requirements that weaken Canada’s
status as the global leader in exploration and mining. While we
welcome recent proposals to allow more Canadians to participate
in the opportunities our industry presents, for example, through
new or expanded prospectus exemptions, more needs to be done.
The CCMR presents a vital opportunity to support Canadian
companies in raising the money they need to create jobs and
drive our economy forward. That is why the Prospectors &
Developers Association of Canada commends Saskatchewan,
New Brunswick, Prince Edward Island, British Columbia, Ontario
and the federal government for working towards its creation.
Moreover, while we hope that other provinces will choose to
participate we also hope that they will make their participation
contingent upon a commitment to design a regulatory regime that
unlocks growth, not one that stifles it. In particular, we encourage
the new regulatory regime to include all of the newly proposed
exemptions such as the:
• Offering memorandum exemption
• Family, friends and business associates exemption
• Existing security holders exemption
• Crowdfunding (and start-up crowdfunding) exemption
It goes without saying that governments must strike the
right balance between investor protection on the one hand, and
efficient capital formation on the other. Canadians will not invest in
an industry if they think they will be at risk of being duped, hence,
we support strong enforcement and criminal prosecution of fraud.
The best way to protect investors is to put criminals in jail, not to
impose additional costs on the good guys.
Maintaining strong access to capital is crucial to sustaining
Canada’s economic growth, as well as its standing in the global
economy. We need to ensure that we take proportionate measures
necessary to strengthen this asset, or we will lose our global
position and the potential economic output. The cooperative
regulator creates an opportunity for Canada to strengthen its
status as the best place in the world to raise money for exploration.
We hope this opportunity is not wasted.
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Private Capital Markets Association of Canada