• How to read your client statements in
the private capital markets (e.g., what
‘not determinable’ means)
• How do you set up a registered plan
for private capital market securities
The PCMA would welcome the opportunity to work closer with the ASC in
developing topics of interest that can
provide investors with better more
tailored information about the private
capital markets.
As an example of an excellent investor
education tool, we acknowledge and
appreciate the hard work the ASC has
completed, in consultation with the
ASC’s Exempt Market Dealer Advisory
Committee, in the release of ASC Notice
31-701 – Account Opening Assistance.2
It provided a sample KYC form and
account information explaining, among
other things, what information a Dealing
Representative collects from an investor
and why. It is not uncommon for
investors to ask why an EMD and its
Dealing Representatives have to ask so
many questions, including personal
financial and other information, when
completing a client KYC form and
related documents. This is a very helpful
tool for Dealing Representatives who can
provide this document to investors to
support the requirement to provide KYC
information.
ASC Website – Exempt Market
Dashboard
The PCMA applauds the ASC creation
and further enhancement of its Exempt
Market Dashboard (i.e., Tableau
Public).
3 We recommend certain
enhancements to content, overall
usability and user-friendliness, as set
out below:
• as this is an Alberta initiative, consideration should be given to showcasing
Alberta-based issuers and linking them
to Alberta-based EMDs that have
approved a particular offering for
distribution and sale.
30 THE PRIVATE INVESTOR | FALL+WINTER 2019
• adding information similar to what is
found on the TSX Matrix, but with easy
access to information about private
capital market investment opportunities
and documents for Alberta investors,
such as the issuer’s offering memorandum, related OM marketing materials
and audited annual financial statements.
• consider providing easy access to the
ASC’s existing database of exempt
financings (similar to BCSC eServices)
to provide insights on the size and
nature of financings being reported to
the ASC.
• the ASC states in the Consultation
Paper that it seeks comments on
whether it should encourage certain
limited information to be filed with the
ASC about private financings that are
not currently required to be reported
(e.g., amount raised, price, and security
type). The PCMA suggests the option for
issuers to provide such information,
however, it should not be a requirement.
An issuer should be encouraged to
provide information for investors that
could be used for educational / information purposes rather than providing the
ASC with more information which is
burdensome to an issuer without a
corresponding benefit.
• The website for the ASC Investor
Dashboard is slow and does not appear
to include all data (e.g., missing some
years; when selecting two issuers only
one shows up in the search filter).
• Please ensure the ASC portal is
compatible for all users. SEDAR for
example, will not always display documents on Apple based devices or other
PDF viewers, outside of Adobe.
• We believe that the ASC needs to
create a dashboard that is developed
from the “Eyes of an Investor”. The ASC
Dashboard should include an issuer-
specific site that has all of an issuer’s
information in one place. For example, if
an investor wants to see all filings about
Alberta Business Inc., it should be able
to go to a specific site within the ASC’s
portal that has key information about
the issuer filed with the ASC including:
> the same information as on SEDAR
for reporting issuers (as applicable)
> the issuer’s offering memorandum
(current and past), if applicable, or
another document filed with the ASC
> marketing materials, if available
> audited annual financial statements
(current and past), if available
> news releases, if available
• Such an issuer centric site would
allow investors and market participants
to have more information and transparency about each issuer in a use-friendly
manner. The PCMA would welcome the
opportunity to have further discussions
with the ASC regarding this initiative.
The PCMA strongly recommends that
the ASC initially focus on developing an
investor friendly site dedicated to
Alberta investors, issuers and local
based registrants.
c) Expanding the Accredited Investor
Exemption to include Educated,
Experienced Investors
With the current poor economic situation in Alberta arising from depressed
oil prices and otherwise, it is time for
Alberta to diversify its economy outside
of oil and gas, by increasing capital
formation for start-up and early stage
businesses which are often referred to
as small and medium size enterprises
(“SMEs”). This requires an examination
of how capital is raised under available
prospectus exemptions, including the
accredited investor exemption (the “AI
Exemption”) as set out in section 2.3 of
National Instrument 45-106 – Prospectus Exemptions (“NI 45-106”).
The PCMA supports the ASC idea to
expand the definition of an “Accredited
Investor” (“AI”) under the AI Exemption
to increase the pool of capital for Alberta
issuers and to provide Alberta investors
