Regulation Breaks Down What Investors Really Pay

0 Comments


B.C. Reg. 249/2025 introduces amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, a core component of Canada’s securities regulatory framework governing registrants such as investment dealers, advisers, and investment fund managers. Adopted by the British Columbia Securities Commission under section 184 of the Securities Act. The amendments primarily strengthen cost transparency for investors by requiring more detailed disclosure of investment fund expenses and charges within client reporting.

The amendments introduce several new definitions designed to clarify how investment fund costs are categorized and reported. These include “direct investment fund charge,” which refers to fees charged directly to a client when they buy, hold, sell, or switch securities of an investment fund, excluding costs already embedded within the fund’s operating expenses. The rule also defines the “fund expense ratio,” calculated as the combined percentage of a fund’s management expense ratio and trading expense ratio. Additional terms specify how management and trading expenses are measured, aligning with definitions used in investment fund disclosure standards. The amendments also define a “newly-established investment fund,” identifying funds that have not yet produced a management report of fund performance or have existed for less than twelve months.

To ensure registrants can properly report costs to clients, the regulation replaces section 14.1.1 with a new requirement obligating registered investment fund managers to provide dealers and advisers with the information necessary to fulfill client disclosure obligations. This information must be supplied within a reasonable timeframe and supports several reporting provisions under the instrument. The rule effectively formalizes the data-sharing responsibilities between investment fund managers and the registrants who distribute their products.

The amendments further introduce a standardized method for calculating daily fund expenses per security. Under the new formula, the fund expense ratio for a given day is multiplied by the market value of a security in the relevant fund class or series to determine the expense attributable to that security. Investment fund managers may use approximations where exact data is unavailable, provided the result does not mislead clients. Newly established funds are exempt from certain reporting requirements related to fund expenses and ratios, recognizing that sufficient historical data may not yet exist.

Additional interpretive guidance clarifies the meaning of “reasonable approximation” within the British Columbia regulatory context. The rule notes that references to reasonableness are included primarily for clarity and should not alter the interpretation of other securities legislation. It also emphasizes that approximations must still be credible and accurate; unreasonable values will not satisfy disclosure requirements even where other instruments refer to approximate figures.

British Columbia (249/2025) March 10, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.