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.
- 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.