Davies Comments on Proposed Amendments to National Instrument 81-102 Investment Funds

Davies recently submitted a comment letter in response to public consultations initiated by the Canadian Securities Administrators (CSA) regarding proposed amendments to National Instrument 81-102 Investment Funds concerning liquidity risk management, as published by the Canadian Securities Administrators on November 27, 2025, including the concepts discussed in the consultation paper.

The comment letter, prepared by Jean-Philippe Joyal and Adam Curran, delves into the implications of extending liquidity risk management requirements to private investment funds, raising key concerns about regulatory overreach into a market segment that is already subject to appropriate oversight through registration requirements under National Instrument 31-103. It further explains why Davies advocates for a more tailored, principles-based approach to regulation.

Download the comment letter to learn more about this intersection of law, finance and policy.