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March 19, 2013

Autorité des marchés financiers
800, square Victoria, 22e étage
C.P. 246, tour de la Bourse
Montréal, QB H4Z 1G3
Sent via e-mail to: financementdessocietes@lautorite.qc.ca

RE: Notice of Consultation – Offering Memorandum Exemption and Equity Crowdfunding


 

 FAIR Canada is pleased to offer comments on the consultation by the Autorité des marchés financiers (“AMF”) issued through its Notice of Consultation – Offering Memorandum Exemption and Equity Crowdfunding on considerations for new capital raising prospectus exemptions.

FAIR Canada is a national, non-profit organization dedicated to putting investors first. As a voice of Canadian investors, FAIR Canada is committed to advocating for stronger investor protections in securities regulation. Visit www.faircanada.ca for more information.

FAIR Canada Comments

FAIR Canada has provided comments to the Ontario Securities Commission (“OSC”) in respect of OSC Staff Consultation Paper 45-710 Considerations for New Capital Raising Prospectus Exemptions. While the OSC paper considered a broader spectrum of potential prospectus exemptions, the OSC paper did discuss a possible offering memorandum exemption and an equity crowdfunding exemption, in order to assist SMEs raise capital and we believe that the OSC’s rationale for undertaking its review is substantially similar to the AMF’s consultation.

Given that FAIR Canada has expressed its views regarding capital raising in the exempt market generally, as well as its views on the offering memorandum and equity crowdfunding more specifically, in our submission to the OSC, we herein submit our views and comments to the AMF as expressed to the OSC on March 8, 2013. We also attach a copy of our press release in respect of equity crowdfunding.

We note that FAIR Canada also submitted related comments (dated February 20, 2013) in response to Multilateral CSA Notice 45-311 relating to the AMF’s December 20, 2012 blanket order exempting certain issuers from some of the requirements in respect of the offering memorandum exemption.

We thank you for the opportunity to provide our comments and views in this submission. We welcome its public posting and would be pleased to discuss this letter with you at your convenience. Feel free to contact Ermanno Pascutto at 416-214-3443 (ermanno.pascutto@faircanada.ca) or Marian Passmore at 416-214-3441 (marian.passmore@faircanada.ca).

Sincerely,

Canadian Foundation for Advancement of Investor Rights

Encls.
1) FAIR Canada submission RE: OSC Exempt Market Review: OSC Staff Consultation Paper 45-710 Considerations for New Capital Raising Prospectus Exemptions (March 8, 2013)
2) FAIR Canada Press Release (March 18, 2013)