More BMO comments … elimination of registration exemptions
com_20080529_31-103_shadowitzr.pdf (application/pdf Object)
… As the current draft of the Instrument can now be read in conjunction with a proposed draft of National Instrument 45-106 Prospectus and Registration Exemptions (NI 45-106) which anticipates the coming-into-effect of the business trigger we reiterate our concern that, as drafted, the elimination of certain registration exemptions will negatively impact banks and other market participants from carrying on certain activities that have been conducted by them for decades under existing registration exemptions.
