com_20080528_31-103_ladnerb.pdf (application/pdf Object)

 However, there is some uncertainty
whether an exempt market dealer would be required to adhere to these same conduct
rules and obligations with respect to its dealings, from within Canada, with investors
resident outside of Canada, in particular where the activities are such that they would
not otherwise require registration in Canada. For example, an existing foreign
investor wishing to switch from one Orbis Fund to another may telephone the Orbis
call centre in British Columbia to enquire about the mechanics of doing so. Our client
considers that the mere provision of administrative information by a representative of
an exempt market dealer should not precipitate the need for a suitability review of the
investment decision of a foreign investor in relation to their investment in an
investment fund or other issuer located outside of Canada, on the basis that the laws of
the jurisdictions where the investor and the issuer are located should appropriately
regulate these activities.