Regulatory
Submissions
Regulatory Submissions
The following are the Coalition’s submissions on regulatory initiatives on important governance issues. Click on the year to go directly to submissions for that year.
Each publication was developed in consultation with our members and experts in the related field.
- CCGG comment to Ontario Securities Commission (“OSC”) Notice 11-798–Statement of Priorities: Request for Comments Regarding Statement of Priorities for Financial Year 2024 -2025
- CCGG comment to Canadian Public Accountability Board’s (CPAB) request for comment: proposed rule changes
- CCGG Submission to CSA Re: CSA Notice and Request for Comment – Proposed Amendments to Form 58-101F1 Corporate Governance Disclosure of National Instrument 58-101 Disclosure of Corporate Governance Practices and Proposed Changes to National Policy 58-201 Corporate Governance Guidelines
- CCGG Response to ISSB’s Request for Information – Consultation on Agenda Priorities
- CCGG Letter to CSA – Request to Pause Access Equals Delivery
Each publication was developed in consultation with our members and experts in the related field.
- CCGG Letter to OSC Re: Ontario Securities Commission (“OSC”) Notice 11-797 –Statement of Priorities: Request for Comments Regarding Statement of Priorities for Financial Year to End March 31, 2024
- CCGG Letter to CSA Re: CSA’s Climate change-related disclosures update
- CCGG Submission to OECD Re: Public Consultation on Draft Revisions to the G20/OECD Principles of Corporate Governance
- CCGG Submission Re: Corporate Governance Consultation
- CCGG_IFRS ISSB Re S2 -Climate-related Disclosures
- CCGG_IFRS ISSB Re S1 General Sustainability Requirements
- CCGG Submission to CSA – Proposed Amendments to Implement an Access Equals Delivery Model
- CCGG Submission to US SEC Re: Enhancement and Standardization of Climate-related Disclosures
- CCGG Submission Re: Capital Markets Act Consultation
- CCGG Letter to CSA Re: CSA Consultation Climate-related Disclosure Update and CSA Notice and Request for Comment Proposed National Instrument 51-107 Disclosure of Climate-related Matters
Each publication was developed in consultation with our members and experts in the related field.
- CCGG Submission to Ontario Securities Commission re request for comment on Notice 11-794 – Statement of Priorities (2022-2023)
- CCGG Submission to the US Department of Labor re Proposed reforms to ERISA fiduciary duty and ESG integration
- CCGG Letter to CSA – Dual Class Shares Policy
- CCGG Final Submission to CSA re Continuous Disclosure and Semi Annual Reporting
- CCGG Submission to SEC – Public Input on Climate Change Related Disclosures
- CCGG Submission – Reopening comment period on Universal Proxies
- CCGG Australian Submission- Treasury Consultation Paper – Greater Transparency of Proxy Advice
- CCGG Comment re Majority Voting Regulations
- CCGG Submission – C-97 Regulatory Consultation concerning executive compensation and the well-being of employees, retirees and pensioners
- CCGG Feedback Letter Attachment to Ontario MGCS Re: Business Corporations
Each publication was developed in consultation with our members and experts in the related field.
- CCGG Submission Re: IFRS Foundation Consultation Paper on Sustainability Reporting
- CCGG Submission re Notice 11-791 2021-2022 SOP
- CCGG Submission – Re: Consultation – Modernizing Ontario’s Capital Markets
- CCGG submission to the US Department of Labor re Proposed ERISA ESG integration regulation
- CCGG extension request to US Department of Labor re Proposed ERISA ESG integration regulation
- CCGG Submission to CSA – National Instrument 52-112: Non GAAP and Other Financial Measures
- CCGG Submission to OSC re 2020-21 Statement of Priorities
- CCGG Submission to CSA – Access equals delivery
- Letter to SEC re Shareholder proposal thresholds
- Letter to SEC re proxy advisor regulation
Each publication was developed in consultation with our members and experts in the related field.
- Letter to CSA Re: BAR Requirement Amendments
- Letter to Ontario Ministry of Government and Consumer Services Re: OBCA Amendments
- Letter to Ontario Securities Commission (“OSC”) Draft 2019-2020 Statement of Priorities
- Letter to SEC Re: Proxy Advisors
- Submission to the Ontario Securities Commission: Burden Reduction
Each publication was developed in consultation with our members and experts in the related field.
- Letter to Canadian Securities Administrators on Approach to Director and Audit Committee Member Independence
- Letter to Canadian Securities Administrators on Non-GAAP and other Financial Measures
- CCGG Senate Brief: Bill C-25
- Letter to the British Columbia Securities Commission on Gender and Other Diversity, April 2018
- Letter to OSC Statement of Priorities 2018-2019
- Letter to PEI government requesting majority voting and other amendments to PEI’s corporate statute
- Letter to Canadian Securities Commissions on Soliciting Dealer Arrangements
Each publication was developed in consultation with our members and experts in the related field.
- Follow up submission to the Department of Finance Canada on the Second Consultation on the Review of the Federal Financial Sector Framework Potential Policy Measures
- Submission to the Ontario Securities Commission re: CSA Consultation Paper 51-404 Considerations for Reducing Regulatory Burden for Non-Investment Fund Reporting Issuers
- Submission to the Department of Finance Canada on the Second Consultation on the Review of the Federal Financial Sector Framework Potential Policy Measures
- Submission to the Ontario Securities Commission on its request for comments on Draft 2017-2018 Statement of Priorities
- Letter to the Prime Minister on Bill C-25 re: Majority Voting, Diversity Disclosure and other matters
- Submission to the TSX re: Comment letter on proposed TSX amendments re disclosure of security based compensation arrangements
- Submission to the House Standing Committee on Industry, Science and Technology re: Amendments to the Canada Business Corporations Act proposed in Part 1 of Bill C-25
- Submission to the Supreme Court of Canada re: CCGG’s Intervener Factum in Livent Inc. vs Deloitte LLP
Each publication was developed in consultation with our members and experts in the related field.
- Letter to Alberta government on adopting CSA gender diversity disclosure requirements
- Letter to Alberta government on amendments to the shareholder proposal provisions of the Alberta Business Corporations Act
- Submission to OSC re: Draft 2016-2017 Statement of Priorities
- Submission to the TSX re: Comment letter on proposed TSX amendments re disclosure of security based compensation arrangements
- Letter to the U.S. Senate Committee on Banking, Housing and Urban Affairs in support of the Council of Institutional Investors’ letter against the proposed regulation of proxy advisors
- Submission to the Alberta Securities Commission Re: Request for Comments on proposed amendments to National Instrument 58-101 Disclosure of Corporate Governance Practices and Form 58- 101Fl Corporate Governance Disclosure regarding gender diversity and term limits
- Submission to the Department of Finance Canada on consultation paper reviewing the federal financial sector framework
- Submission to Ministry of Government and Consumer Services re: Ontario Business Law Advisory Council Report
Each publication was developed in consultation with our members and experts in the related field.
- Submission to the CSA re: Request for Comments on proposed amendments to Multilateral Instrument 62-104 Take-Over Bids and Issuer Bids and proposed changes to National Policy 62-203 Take-Over Bids and Issuer Bids
- Submission to TSX and OSC re: Request for Comments on Proposed Amendments to TSX Company Manual to modify, expand and formalize certain exemptions available to interlisted issuers
- Submission to OSC re: OSC Staff consultation Paper 15-401 Proposed Framework for an OSC Whistleblower Program
- Submission to the Ministry of Government and Consumer Services re: Comments on Ontario Business Law Agenda on Priority Findings & Recommendations Report
Each publication was developed in consultation with our members and experts in the related field.
- Submission to the OSC re: Request for Comments on Proposed Amendments to National Instrument 58-101 Disclosure of Corporate Governance Practices Regarding Women on Boards and in Senior Management
- Submission to the Industry Canada re: Industry Canada Consultation on the Canada Business Corporations Act
- Submission to ICGN re: ICGN Member Consultation on Draft ICGN Global Governance Principles
- Submission to the OSC re: Ontario Securities Submission Draft 2014-2015 Statement of Priorities
- Submission to the CSA re: Request for Comments on Proposed National Policy 25-201 Guidance for Proxy Advisory Firms
- Submission to the CSA re: Request for Comments on Venture Issuer regulation
- Submission to the CSA re: Request for Comments on Proposed Amendments regarding gender diversity and term limits
- Submission to Cooperative Capital Markets Regulatory Authority re: Draft Provincial and Federal Legislation regarding the Cooperative Capital Markets Regulatory System
- Submission to Cooperative Capital Markets Regulatory Authority re: Draft Provincial and Federal Legislation regarding the Cooperative Capital Markets Regulatory System
- Submission to the CSA re: Request for Comments on Proposed Amendments regarding gender diversity and term limits
Each publication was developed in consultation with our members and experts in the related field.
- Submission to the TSX re: December, 2012 Consultation Paper on Emerging Market Issuers
- Submission to ICGN re: ICGN Position Paper on Gender Diversity
- Submission to the OSC re: Ontario Securities Commission (”OSC”) Draft 2013-2014 Statement of Priorities
- Submission to the CSA and to the AMF re: Proposed National Instrument 62-105 Security Holder Rights Plans and re: Takeover Bid Defensive Tactics
- Submission to the CSA re: Proposed Amendments to National Instrument 62-103 The Early Warning System
- Submission to the NYSE re: Request by the U.S. Council of Institutional Investors that NYSE adopt a majority voting listing standard in uncontested elections of directors
- Submission to the NASDAQ re: Request by the U.S. Council of Institutional Investors that NASDAQ adopt a majority voting listing standard in uncontested elections of directors
- Submission to the OSC re: OSC Staff Consultation Paper 58-401 Disclosure Requirements Regarding Women on Boards and in Senior Management (the “Consultation Paper”)
- Submission to the OSC re: CSA Consultation Paper 54-401 Review of the Proxy Voting Infrastructure (the “Consultation Paper”)
Each publication was developed in consultation with our members and experts in the related field.
- Submission to the OSC re: Ontario Securities Commission’s draft 2012-2013 Statement of Priorities
- Submission to the CSA re: Consultation Paper 25-401: Potential Regulation of Proxy Advisory Firms
- Submission to the TSX re: September 9, 2012 Proposed Amendments to Part IV of the TSX Company Manual
- Submission to the TSX re: October 4, 2012 Proposed Amendments to the TSX Company Manual to require TSX-listed issuers to adopt Majority Voting Policies
- Submission to the CSA re: Proposed National Instrument 51-103 Ongoing Governance and Disclosure Requirements for Venture Issuers
Each publication was developed in consultation with our members and experts in the related field.
- CCGG Letter of Response to the CSA Submission on Compensation Disclosure
- CCGG Senate Brief: Women on Boards
- CCGG Letter of Response to the OSC Staff Notice 54-701: Regulatory Developments Regarding Shareholder Democracy Issues
- CCGG Letter of Response to the Application for Recognition of Alpha Trading Systems Limited Partnership and Alpha Exchange Inc. as an Exchange
- CCGG Letter of Response to the Proposed Amendments to Part IV of the Toronto Stock Exchange Company Manual
- CCGG Letter of Response to the Proposed National Instrument 51-103 Ongoing Governance and Disclosure Requirements for Venture Issuers
- CCGG Letter of Response to OSC re: Maple Group Acquisition Corporation Notice and Request for Comment
- CCGG Letter of Response to the OSC Staff Notice 15-704: Request for Comments on Proposed Enforcement Initiatives
Each publication was developed in consultation with our members and experts in the related field.
- Report of the Standing Committee on Industry, Science and Technology
- CCGG Submission to the Parliamentary Committee on Industry, Science, and Technology Regarding the Statutory Review of the Canada Business Corporations Act (CBCA)
- CCGG Letter to the CSA Regarding the Early Warning Threshold
- CCGG Application for Leave to Intervene on Federal Securities Act Constitutional Reference
- CCGG Letter of Response to the Proposed Changes to NI 43-101 Standards of Disclosure for Mineral Projects
- CCGG Letter of Response to the Proposed Amendements to NI 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer
- CCGG Letter of Response to the CSA Multilateral Consultation Paper 51-403 (Venture Issuer Proposal)
- CCGG Letter of Response to the Proposed NI 25-101 – Designated Rating Organizations, Related Policies and Consequential Amendments
- CCGG Letter of Response to the Concept Release on the US Proxy System
- CCGG Factum in the Supreme Court of Canada
Each publication was developed in consultation with our members and experts in the related field.
- Letter to the SEC on eliminating Broker Votes
- Doug Pearce’s (CCGG Chair) letter to the CSA outlining the CCGG’s concerns with respect to shareholder democracy
- Canadian Coalition for Good Governance comments to the CSA on the proposed changes to the corporate governance guidelines
- Canadian Coalition for Good Governance comments to the TSX on the proposed changes to Part VI of the Company Manual – shareholder approval in dilutive transactions
Each publication was developed in consultation with our members and experts in the related field.
- Canadian Coalition for Good Governance comments to the CSA on National Instrument 51-102 (Proxy Solicitation Provisions)
- Canadian Coalition for Good Governance comments on the Canadian Securities Administrators (CSA) Concept Paper 52-402 on possible changes to securities rules relating to International Financial Reporting Standards
- Canadian Coalition for Good Governance submission to the Ministère des Finances du Québec responding to the Working Paper on the Reform of the Quebec Corporations Act
- Canadian Coalition for Good Governance comments on proposed Form 51-102 F6 (Compensation Disclosure)
- Canadian Coalition for Good Governance comments on the Canadian Performance Reporting Board’s exposure draft “Improved Communication with Non-GAAP Finanical Measures”
- Canadian Coalition for Good Governance comments to the Expert Panel on Securities Regulation
Each publication was developed in consultation with our members and experts in the related field.