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

… We are concerned that the current exemption for short term debt has not been continued in the Instrument. The removal of this exemption would preclude banks and other non-registered firms from continuing to trade in products such as commercial paper without registration, absent any provincial exemption. This would be a significant change to the status quo and a step-back from harmonization.
While we are pleased to see that the exemption for short-term debt will be continued in Ontario under Ontario Securities Commission Rule 45-501 Ontario Prospectus and Registration Exemptions (OSC Rule 45-501) we are disappointed to see that this exemption will not be continued across Canada.