ASC Consultation Paper 11-701 – Energizing
Alberta’s Capital Market
e believe the ASC is
demonstrating its contin-
ued leadership as a
member of the Canadian
Securities Administrators
(the “CSA”) in examining new and better
ways to foster a more vibrant Alberta
capital market that can better address
the financing needs of emerging and
growing Alberta businesses while
maintaining important investor protec-
tion safeguards.
The PCMA’s comments are in connection with brainstorming ideas (a), (b),
(c), (d), (e), (f) and (g).
Responses to specific brainstorming
ideas in the Consultation Paper
a) Informational Resources for Alberta
start-ups and early stage businesses on
capital raising options
b) Informational Resources for Investors investing in Alberta Businesses
We have combined our response to both
brainstorming ideas for issuers and
investors. The PCMA strongly supports
any ASC initiative to improve resources
dedicated to investor education and
information for new for Alberta start-ups
and early stage businesses on capital
raising options in the private capital
markets. We believe these resources can
be delivered electronically through the
ASC website and include You Tube
videos, live and recorded webinars and
other digital-based media.
Investor Education and Websites
As investor education resources and
tools are common among all CSA
members, for your ease of reference,
we have identified certain examples of
investor information on select CSA
member websites that we think are good
resources. We have provided select
comments and observations in Schedule A.
We also reviewed the ASC’s current
website that it relaunched in 2019, and
have similarly provided comments as a
means of addressing these brainstorming topics.
ASC Website – Investor Dashboard
The PCMA supports the continued
development of the ASC Checkfirst1
Investor Dashboard (the “ASC Investor
Dashboard”). Upon review of the ASC’s
investor education videos, we believe
they can be grouped into two types:
Investing 101 Videos - general investor
education, and Investment Fraud Videos
- warning videos. The first type of videos
includes information about RRSPs and
TFSAs, developing a financial plan and
basic financial concepts. The second
type of videos include information about
affinity fraud, pump and dump schemes,
recognizing and avoiding Ponzi
schemes, and victim testimonials.
The PCMA believes that information
about the private capital markets and
exempt market dealers (“EMDs”) is
missing and applauds the ASC efforts in
creating an Exempt Market Dashboard
as discussed below under “ASC Website
– Exempt Market Dashboard”. It is in
the private capital market where start-
ups and early stage businesses will likely
find options for raising capital. It is the
ASC’s mandate to develop fair and
efficient capital markets as well as
protecting investors.
The PCMA believes information on the
ASC Investor Dashboard should include,
by video or downloadable documents,
more information about the private
capital markets, including, but not
limited to, the following topics:
• What is the difference between the
private and public capital markets
• What are prospectus exemptions and
how are they used to finance businesses
and create jobs in Alberta
• How the offering memorandum
exemption works to raise capital in
Alberta
• What is the role of an EMD and its
Dealing Representatives in the capital
raising process
• What is the role of an issuer when
raising capital and how do they work
with an EMD
• Risk and reward considerations when
investing
• Explaining the purpose of the risk
acknowledgement forms
• What documents should an investor
read when considering an investment
• How to work with a dealing representative in completing your know-your
–client (“KYC”) form and subscription
agreement
• Redemptions and liquidity in the
private capital markets
W
PCMA COMMENT LETTER
The Private Capital Markets Association of Canada (the “PCMA”) is pleased to provide our comments
in connection with the Alberta Securities Commission’s (the “ASC”) Consultation Paper.
