Fidelity Investments Canada ULC (Re), 2025 CanLII 49690

May 1, 2025

(the Jurisdiction)

AND

(FIC)

Background

The principal regulator in the Jurisdiction has received an application from FIC for a decision under the securities legislation of the Jurisdiction (the Legislation):

(a) for an exemption from the prohibition in subsection 4.2(1) of National Instrument 81-102 Investment Funds (NI 81-102) to permit the NI 81-102 Funds (as hereinafter defined) to purchase debt securities from, or sell debt securities to an International Fund (as hereinafter defined) (the Section 4.2(1) Relief);

(b) for an exemption from the prohibitions in subparagraphs 13.5(2)(b)(ii) and (iii) of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) which prohibit a registered adviser from knowingly causing an investment portfolio managed by it, including an investment fund for which it acts as an adviser, to purchase or sell a security from or to the investment portfolio of an associate of a responsible person or an investment fund for which a responsible person acts as an adviser, in order to permit:

(i) a Canadian Fund (as hereinafter defined) to purchase securities from or sell securities to an International Fund (as hereinafter defined); and

(ii) a Canadian Client Account (as hereinafter defined) to purchase securities from or sell securities to an International Fund (as hereinafter defined);

(each transaction listed in (i) and (ii) above, an International Inter-Fund Trade, and, collectively referred to herein as the International Inter-Fund Trading Relief). The Section 4.2(1) Relief and the International Inter-Fund Trading Relief are collectively referred to herein as the Relief Sought.

Under National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application; and

(b) FIC has provided notice that subsection 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon by the Filer (as hereinafter defined) in each jurisdiction of Canada outside of Ontario (together with Ontario, the Jurisdictions).

Interpretation

Terms defined in National Instrument 14-101 Definitions, NI 81-102, NI 31-103 or in MI 11-102 have the same meaning if used in this decision, unless otherwise defined. The following terms have the following meanings:

(a) AIFMD means Directive 2011/61/EU of the European Parliament and of the Council of the European Union of 8 June 2011 on Alternative Investment Fund Managers, as amended;

(b) Applicable Inter-Fund Trading Policies has the meaning given to it in Representation 26;

(c) Canadian Client Account means an account managed by the Filer (as hereinafter defined) that is beneficially owned by a client that is resident or domiciled in Canada and is not a responsible person, and over which the Filer (as hereinafter defined) has discretionary authority;

(d) Canadian Clients means, collectively, the NI 81-102 Funds (as hereinafter defined), the Canadian Pooled Funds (as hereinafter defined) and the Canadian Client Accounts;

(e) Canadian Funds means, collectively, the NI 81-102 Funds (as hereinafter defined) and the Canadian Pooled Funds (as hereinafter defined);

(f) Canadian Pooled Funds means, collectively, the Existing Canadian Pooled Funds (as hereinafter defined) and the Future Canadian Pooled Funds (as hereinafter defined);

(g) Exchange-traded Security has the same meaning as in section 1.1 of National Instrument 21-101 Marketplace Operation;

(h) Existing Canadian Pooled Fund means each investment fund domiciled in Canada that is not a reporting issuer, and to which NI 81-102 and NI 81-107 do not apply, for which FIC acts as the investment fund manager and the Filer (as hereinafter defined) acts as portfolio manager;

(i) Existing International Pooled Fund means each existing investment fund that is domiciled in the United Kingdom, Ireland, Luxembourg or Hong Kong and exempt from registration in the applicable foreign jurisdiction, for which a FIC Sub-adviser (as hereinafter defined) or an affiliate of a FIC Sub-adviser (as hereinafter defined) acts as manager and/or portfolio manager;

(j) Existing International Retail Fund means each existing investment fund that is domiciled in the United Kingdom, Ireland, Luxembourg or Hong Kong and offered by way of a prospectus (or similar offering document) that is filed with the applicable securities regulatory authority in the foreign jurisdiction, for which a FIC Sub-adviser (as hereinafter defined) or an affiliate of a FIC Sub-adviser (as hereinafter defined) acts as manager and/or portfolio manager;

(k) Existing NI 81-102 Fund means each existing investment fund that is a reporting issuer, and to which NI 81-102 and NI 81-107 apply, for which FIC acts as the investment fund manager and the Filer (as hereinafter defined) acts as portfolio manager;

(l) FIC Sub-adviser means those entities within the larger Fidelity enterprise which provide advice with respect to all or a portion of the investments of the Canadian Clients and FIC Sub-adviser shall mean any one of them;

(m) Filer means FIC and any affiliate of FIC that is registered as an adviser (portfolio manager) in any Jurisdiction;

(n) Funds means, collectively, the Canadian Funds and the International Funds (as hereinafter defined and each, a Fund);

(o) Future Canadian Pooled Fund means each investment fund, to be established in the future, that will be domiciled in Canada that will not be a reporting issuer, and to which NI 81-102 and NI 81-107 will not apply, for which FIC will act as the investment fund manager and the Filer will act as portfolio manager;

(p) Future International Pooled Fund means each investment fund, to be established in the future, that will be domiciled in the United Kingdom, Ireland, Luxembourg or Hong Kong and will be exempt from registration in the applicable foreign jurisdiction, for which a FIC Sub-adviser or an affiliate of a FIC Sub-adviser acts as manager and/or portfolio manager;

(q) Future International Retail Fund means each investment fund, to be established in the future, that will be domiciled in the United Kingdom, Ireland, Luxembourg or Hong Kong and will be offered by way of a prospectus (or similar offering document) that is filed with the applicable securities regulatory authority in the foreign jurisdiction, for which a FIC Sub-adviser or an affiliate of a FIC Sub-adviser acts as manager and/or portfolio manager;

(r) Future NI 81-102 Fund means each investment fund to be established in the future, that will be a reporting issuer, and to which NI 81-102 and NI 81-107 will apply, for which FIC will act as the investment fund manager and the Filer will act as portfolio manager;

(s) Hong Kong Regulations means, collectively, (i) the Mandatory Provident Fund Schemes Ordinance (Chapter 485 of the Laws of Hong Kong) and its subsidiary legislation and (ii) the Securities and Futures Ordinance (Chapter 571 of the Laws of Hong Kong), its subsidiary legislation and related Codes promulgated by the Hong Kong Securities and Futures Commission thereunder;

(t) Inter-Fund Trades means the International Inter-Fund Trades and, where applicable, all trades made pursuant to the Section 4.2(1) Relief;

(u) International Funds means, collectively, the Existing International Pooled Funds, the Future International Pooled Funds, the Existing International Retail Funds and the Future International Retail Funds;

(v) International Pooled Funds means, collectively, the Existing International Pooled Funds and the Future International Pooled Funds;

(w) International Regulations means, collectively, the UK Regulations (as hereinafter defined), the Irish Regulations (as hereinafter defined), the Luxembourg Regulations (as hereinafter defined) and the Hong Kong Regulations;

(x) International Retail Funds means, collectively, the Existing International Retail Funds and Future International Retail Funds;

(y) IRC means the independent review committee of the Canadian Funds, and for greater certainty includes the Pooled Fund IRC (as hereinafter defined);

(z) Irish Regulations means, collectively, (i) the AIFMD, (ii) the European Union (Alternative Investment Fund Managers) Regulations, 2013, (iii) the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Undertakings for Collective Investment in Transferable Securities) Regulations 2019, as amended, and (iv) the UCITS Regulations (as hereinafter defined);

(aa) Luxembourg Regulations means, collectively, (i) the AIFMD, (ii) the Commission de Surveillance du Secteur Financial Circular 18/698 relating to authorisation of and organisation of investment fund managers incorporated under Luxembourg law, (iii) the Luxembourg Law of 13 February 2007 relating to specialised investment funds, as amended, (iv) the Luxembourg Law dated 17 December 2010 relating to undertakings for collective investment, as amended, and (v) the UCITS Regulations (as hereinafter defined);

(bb) Marketplace has the same meaning as in section 1.1 of National Instrument 21-101 Marketplace Operation;

(cc) NI 81-102 Funds means, collectively, the Existing NI 81-102 Funds and the Future NI 81-102 Funds;

(dd) Pooled Fund IRC means the IRC to be established for the Canadian Pooled Funds as contemplated in Representation 29;

(ee) Third-Party CIRO Registered Dealer means a dealer that is not the Filer and is registered with the Canadian Investment Regulatory Organization;

(ff) UCITS Regulations means the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011, as amended; and

(gg) UK Regulations means, collectively, (i) the Alternative Investment Fund Managers (Amendment etc.) (EU Exit) Regulations 2019 (UK SI 2019/328), (ii) the Collective Investment Schemes (Amendment etc.) (EU Exit) Regulations 2019 (UK SI 2019/325) and (iii) the rules and guidance made by the Financial Conduct Authority (FCA) pursuant to the Financial Services and Markets Act 2000 as set forth in the FCA Handbook.

Representations

This decision is based on the following facts represented by the Filer:

The Filer

FIC is a corporation amalgamated under the laws of Alberta, with its head office in Toronto, Ontario. FIC is registered as an adviser in the category of portfolio manager and mutual fund dealer in each of the Jurisdictions and is registered under the Commodity Futures Act (Ontario) (CFA) in the category of commodity trading manager. FIC is registered as an investment fund manager under the relevant securities legislation of the provinces of Ontario, Quebec and Newfoundland and Labrador.
FIC acts or will act as investment fund manager of each of the Canadian Funds.
FIC is or will be the portfolio manager for the Canadian Clients. FIC has entered into sub-advisory agreements with the FIC Sub-advisers to provide advice with respect to all or a portion of the investments of the Canadian Clients. The FIC Sub-advisers may change from time to time.
The Filer and each of the Canadian Clients are not in default of the securities legislation of any Jurisdiction.

The Canadian Clients

Each NI 81-102 Fund is or will be an open-end investment fund trust created under the laws of Ontario or a class of shares of a corporation incorporated under the laws of the Province of Alberta.
The securities of each of the NI 81-102 Funds are or will be qualified for distribution in some or all of the Jurisdictions pursuant to prospectuses prepared in accordance with applicable securities legislation and filed with and receipted by the securities regulators in each of the applicable Jurisdictions.
Each of the NI 81-102 Funds is or will be a reporting issuer in one or more of the Jurisdictions.
FIC has established the IRC in respect of the NI 81-102 Funds in accordance with NI 81-107. Any Future NI 81-102 Fund will also be within the mandate of the IRC.
Each Canadian Pooled Fund is or will be an open-end investment fund trust created under the laws of Ontario.
The securities of each of the Canadian Pooled Funds are distributed by way of an applicable prospectus exemption as permitted by National Instrument 45-106 Prospectus Exemptions.
FIC offers discretionary investment management services to institutional investors in Canada through the Canadian Client Accounts.
Each Canadian client wishing to receive discretionary investment management services from FIC has entered into, or will enter into, a written agreement whereby the client appoints FIC to act as portfolio manager in connection with an investment portfolio of the client with full discretionary authority to trade in securities for the Canadian Client Account without obtaining the specific consent of the client to execute the trade.

The International Funds

Each International Retail Fund is, or will be, established under the laws of the United Kingdom, Ireland, Luxembourg or Hong Kong and offered by way of a prospectus (or similar offering document) that is filed with the applicable securities regulatory authority in the foreign jurisdiction.
Each International Pooled Fund is, or will be, established under the laws of the United Kingdom, Ireland, Luxembourg or Hong Kong, and exempt from registration in the applicable foreign jurisdiction. Shares of the International Pooled Funds are, or will be, distributed on a private placement basis pursuant to exemptions from the registration requirements set forth in the International Regulations, as applicable.

The Inter-fund Trades

The Filer wishes to be able to permit any Canadian Client to engage in Inter-Fund Trades of portfolio securities with an International Fund.
NI 31-103, NI 81-102 and NI 81-107 restrict inter-fund trading. Absent the Relief Sought, none of the Canadian Clients, nor the Filer on their behalf, will be permitted to engage in Inter-Fund Trades as contemplated in this decision.
The Filer is a responsible person for the purpose of paragraph 13.5(2)(b) of NI 31-103 and, absent exemptive relief, is prohibited from effecting any Inter-Fund Trades between Canadian Clients and International Funds (as investment funds for which the Filer, or other responsible person, acts as an adviser).
Each FIC Sub-adviser which is an affiliate of the Filer and has access to, or participates in, formulating, an investment decision made on behalf of the Canadian Clients is a responsible person for the purpose of paragraph 13.5(2)(b)) of NI 31-103. As responsible persons, absent the Relief Sought, each such FIC Sub-adviser is prohibited from effecting any Inter-Fund Trades between Canadian Clients and International Funds (as investment funds for which the Filer, or other responsible person, acts as an adviser).
Absent exemptive relief, each NI 81-102 Fund is prohibited under subsection 4.2(1) of NI 81-102 from purchasing a security from or selling a security to an International Fund (if the International Fund is an associate or an affiliate of the Filer).
The exception in section 4.3(1) of NI 81-102 which permits certain inter-fund trades of securities subject to public quotations is not available for Inter-Fund Trades of debt securities because debt securities are typically not subject to public quotations.
The exception in section 4.3(2) which permits certain inter-fund trades of debt securities is not available for any Inter-Fund Trades of debt securities between NI 81-102 Funds and International Funds. In this instance, that exemption only applies where funds on both sides of the inter-fund trade are investment funds subject to NI 81-107. The International Funds will not be subject to NI 81-107.
Where a FIC Sub-adviser is a responsible person of the Canadian Clients and also acts as an adviser to an International Fund, any International Inter-Fund Trades between the Canadian Clients and the International Funds would be prohibited under subparagraphs 13.5(2)(b)(ii) or (iii) of NI 31-103. Other Fidelity entities within the Fidelity enterprise are not affiliates of the Filer and, although they may be FIC Sub-advisers and although their activities are overseen by FIC, they are not responsible persons of the Canadian Clients as contemplated by paragraph 13.5(1)(c) of NI 31-103 as they are not the adviser to the Canadian Clients. When these entities act as an adviser to an International Fund, FIC has not, to date, permitted any International Inter-Fund Trades between the Canadian Clients and the International Funds, even though these International Inter-Fund Trades are not prohibited under the applicable provisions of NI 31-103.
Overall, the trading conducted within the Fidelity enterprise on its various trading desks is in respect of approximately U.S. $182B of managed assets (as of December 31, 2024), of which trading for the Canadian Clients is a smaller part, being approximately CDN $8B as of that date.
FIC wishes to institute a program allowing for Inter-Fund Trades, so as to optimize the trading that is conducted on the various trading desks and to allow for efficiencies in carrying out this trading, all of which FIC considers to be in the best interests of the Canadian Clients.
Each Inter-Fund Trade will be consistent with the investment objectives of the Fund or Canadian Client Account, as applicable.
The Filer and each FIC Sub-adviser is subject to inter-fund trade and transfer-in-kind policies (the Applicable Inter-Fund Trading Policies). Such Applicable Inter-Fund Trading Policies include or will include a Canadian specific policy which ensures that Inter-Fund Trades involving a Canadian Client are conducted in accordance with the requirements of applicable securities legislation, including NI 81-102 and NI 81-107.
At the time of an Inter-Fund Trade, the Filer will have policies and procedures in place to enable the Canadian Clients to engage in the Inter-Fund Trades.
Inter-Fund Trades involving an NI 81-102 Fund will be referred to and approved by the IRC of the NI 81-102 Fund under subsection 5.2(1) of NI 81-107 and FIC, as investment fund manager of an NI 81-102 Fund, and the IRC of the NI 81-102 Fund, will comply with section 5.4 of NI 81-107 in respect of any standing instructions the IRC provides in connection with the Inter-Fund Trade. The IRC of the NI 81-102 Funds will not approve an Inter-Fund Trade involving an NI 81-102 Fund unless it has made the determination set out in subsection 5.2(2) of NI 81-107.
FIC, as investment fund manager of the Canadian Pooled Funds, will establish an IRC (which may also be the IRC in respect of the NI 81-102 Funds) in respect of each Canadian Pooled Fund (the Pooled Fund IRC). The sole mandate of the Pooled Fund IRC will be considering and, if appropriate, approving the Inter-Fund Trades made by the Canadian Pooled Funds in reliance upon the Relief Sought. Such approvals may be made by way of standing instruction in the same way as permitted under NI 81-107 for the NI 81-102 Funds.
The Pooled Fund IRC will be composed by FIC, as manager of a Canadian Pooled Fund, in accordance with section 3.7 of NI 81-107 and the IRC will comply with the standard of care set out in section 3.9 of NI 81-107. Further, the Pooled Fund IRC will not approve Inter-Fund Trades unless it has made the determination set out in subsection 5.2(2) of NI 81-107.
The investment management agreement or other documentation in respect of a Canadian Client Account will contain the authorization of the client on behalf of the Canadian Client Account to engage in Inter-Fund Trades.
When the Filer engages in an Inter-Fund Trade of securities between Canadian Clients and International Funds, each will comply with the following procedures:

(a) the portfolio manager of one client (Client A) will deliver the trade instructions in respect of a purchase or a sale of a security by Client A to a trader on the trading desk of the Filer or one of the FIC Sub-advisers;

(b) the portfolio manager of the other client (Client B) will deliver the trade instructions in respect of a purchase or a sale of a security by Client B to a trader on the trading desk of the Filer or one of the FIC Sub-advisers (this may be the same trading desk or a different trading desk than is handling the order for Client A). The portfolio manager of Client A may also be the same individual who is the portfolio manager of Client B;

(c) the traders on the trading desk will have the discretion to execute the trade as an Inter-Fund Trade between Client A and Client B in accordance with the requirements of paragraphs (d) to (g) of subsection 6.1(2) of NI 81-107;

(d) the policies applicable to the trading desks will require that: (i) all orders are to be executed on a timely basis, (ii) orders will be executed for no consideration other than cash payment against prompt delivery of a security, (iii) the transaction is consistent with the investment policies of each Client participating in the transaction as recited in its registration statement or offering documents, and (iv) the transaction complies with all other requirements of applicable securities law; and

(e) the trader on each trading desk will advise the portfolio managers of Client A and Client B of the price at which the Inter-Fund Trade occurs.

Where an Inter-Fund Trade is executed by the Filer without the use of a Third-Party CIRO-Registered Dealer, the Filer will comply with the market integrity requirements as set out in paragraph 6.1(1)(b) of NI 81-107.
If the IRC of a Canadian Fund becomes aware of an instance where FIC did not comply with the terms of any decision document issued in connection with the Inter-Fund Trades, or a condition imposed by securities legislation or by the IRC in its approval, the IRC of the Canadian Fund will, as soon as practicable, notify in writing the securities regulatory authority or regulator which is the Canadian Fund's principal regulator.

Benefits of the Relief Sought

The Filer considers that it would be in the best interests of the Canadian Clients to receive the Relief Sought as it will result in:

(a) cost, potential pricing and timing efficiencies in respect of the execution of transactions for the Canadian Clients; and

(b) less complicated and more reliable compliance procedures, as well as simplified and more efficient monitoring thereof, for the Filer, in connection with the execution of transactions on behalf of the Canadian Clients and the International Funds.

International Funds currently conduct inter-fund trading pursuant to the Applicable Inter-Fund Trading Policies, which comply with inter-fund trading rules set forth in the International Regulations. From a procedural perspective, inter-fund trades involving International Funds are subject to oversight by the applicable sub-adviser trading oversight committee and board of the applicable International Fund and/or International Fund’s sub-adviser. In addition, in order to comply with applicable rules governing inter-fund trades and the Applicable Inter-Fund Trading Policies as noted above, it is explicitly required that no brokerage commissions, fees (except for customary transfer fees) or other remuneration be paid by the accounts in connection with such transactions. Inter-Fund Trades would be conducted on FIC’s portfolio management system, which is monitored by an integrated compliance group including representatives of FIC and its related Fidelity enterprise entities.
FIC has determined that similar regulatory requirements applicable to inter-fund trading in Canada and as set forth in the applicable International Regulations, together with FIC’s compliance systems, creates a framework for conducting Inter-Fund Trades in a manner which minimizes conflicts of interest and promotes best execution, fairness and transparency for all clients.

Decision

The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision.

The decision of the principal regulator under the Legislation is that:

the Section 4.2(1) Relief is granted provided that the following conditions are satisfied:

(a) the Inter-Fund Trade is consistent with the investment objectives of each NI 81-102 Fund and each International Fund involved in the trade;

(b) FIC, as the investment fund manager of an NI 81-102 Fund, refers the Inter-Fund Trade involving such NI 81-102 Fund to the IRC of that NI 81-102 Fund in the manner contemplated by section 5.1 of NI 81-107, and FIC and the IRC of the NI 81-102 Fund comply with section 5.4 of NI 81-107 in respect of any standing instructions the IRC provides in connection with the Inter-Fund Trade;

(c) the IRC of the Canadian Fund involved in the trade has approved the transaction in respect of that Canadian Fund in accordance with the terms of section 5.2 of NI 81-107;

(d) the applicable board of the International Fund, or the trust committee or equivalent of the entity acting as trustee or equivalent of the International Fund, involved as a counterparty to the trade has approved policies and procedures that permit Inter-Fund Trades that require compliance with regulatory requirements in the applicable foreign jurisdictions; and

(e) the Inter-Fund Trade complies with paragraphs (d) to (g) of subsection 6.1(2) of NI 81-107;

the International Inter-Fund Trading Relief is granted provided that the following conditions are satisfied:

(a) the Inter-Fund Trade is consistent with the investment objectives of each of the Canadian Clients and International Funds involved in the trade;

(b) FIC, as the investment fund manager of a Canadian Fund, refers the Inter-Fund Trade involving such Canadian Fund to the IRC of that Canadian Fund in the manner contemplated by section 5.1 of NI 81-107, and FIC and the IRC of the Canadian Fund comply with section 5.4 of NI 81-107 in respect of any standing instructions the IRC provides in connection with the Inter-Fund Trade;

(i) the IRC of the Canadian Fund has approved the Inter-Fund Trade in respect of the Canadian Fund in accordance with the terms of subsection 5.2(2) of NI 81-107;

(ii) the applicable board of the International Fund, or the trust committee or equivalent of the entity acting as trustee or equivalent of the International Fund, involved as a counterparty to the trade has approved policies and procedures that permit International Inter-Fund Trades that require compliance with regulatory requirements in the applicable foreign jurisdictions;

(iii) the Inter-Fund Trade complies with paragraphs (d) to (g) of subsection 6.1(2) of NI 81-107, except that the Filer may satisfy the requirements in paragraph (g) of subsection 6.1(2) by using a Third-Party CIRO Registered Dealer to execute the International Inter-Fund Trade;

(d) in the case of an Inter-Fund Trade between a Canadian Client Account and an International Fund:

(i) the investment management agreement or other documentation in respect of the Canadian Client Account authorizes the Inter-Fund Trade;

from the date of this decision until June 30, 2025, and for each complete six-month period that follows until the Filer is otherwise notified by the principal regulator, (each a Reporting Period), FIC:

(a) prepares a report (the Report) containing the following information for the Reporting Period:

(i) the total value traded in Exchange-traded Securities, for each of the following:

(A) Canadian Funds;

(B) Canadian Client Accounts;

(ii) the total value of Inter-Fund Trades in Exchange-traded Securities, between each of the following:

(A) Canadian Funds and International Funds domiciled in Ireland;

(B) Canadian Funds and International Funds domiciled in the United Kingdom;

(D) Canadian Funds and International Funds domiciled in Hong Kong;

(E) Canadian Client Accounts and International Funds domiciled in Ireland;

(F) Canadian Client Accounts and International Funds domiciled in the United Kingdom;

(G) Canadian Client Accounts and International Funds domiciled in Luxembourg;

(H) Canadian Client Accounts and International Funds domiciled in Hong Kong;

(iii) to the extent such information is available to the Filer in its ordinary course of business, for each of the values provided in response to subparagraph (ii), provide separately the total value of Inter-Fund Trades in Exchange-traded Securities that were not executed on a Marketplace;

(b) sends the Report, within 10 business days from the last calendar day of the Reporting Period, to:

(i) the Investment Management Division of the Ontario Securities Commission by e-mail at imdivision@osc.gov.on.ca; and

(ii) the Trading and Markets Division of the Ontario Securities Commission by e-mail at tradingandmarkets@osc.gov.on.ca.

“Darren McKall”

Darren McKall

Manager, Investment Management Division

Ontario Securities Commission

Application No. 2025/0333

Sedar # : 6289218