com_20080529_31-103_shadowitzr.pdf (application/pdf Object)

 We note however that although the CSA has stated that it will not alter the status quo with respect to the regulation of banks we have discovered some areas where the Instrument may impact banks’ ability to continue to carry on their activities as they do today. We have attempted to itemize some of these concerns below. Our concern is that all of these areas may not be identified and resolved prior to the Instrument coming into effect. In order to avoid this we strongly recommend the CSA include a parallel exemption for financial institutions as is found in section 35.1 of the draft amendments to the Ontario Securities Act.