On May 9, 2019 FAIR Canada made a submission regarding the CSA Second Notice and Request for Comment relating to Syndicated Mortgages. FAIR Canada had commented on syndicated mortgages in June 2018 and wrote about some of our ongoing concerns in the May 2019 submission. We wrote about welcoming the transfer of jurisdiction in regard to regulation of syndicated mortgages from the FSCO to the OSC.
FAIR held that the addition of Form 45-106F18 was useful because it requires the addition of disclosure about the speculative nature of an investment in a syndicated mortgage. While this is an improvement, we echoed our concerns from our June 2018 submission that this risk disclosure does still not go far enough because many retail investors lack sufficient financial literacy to be proficient in financial matters associated with investments in syndicated mortgages. We re-emphasized in our submission that resources within the CSA and OSC should be allocated to encourage compliance and enforcing the rules applicable to syndicated mortgage investments once in place.
To read the full submission click here.