The Securities Commission has granted an exemption to IG Investment Management, Ltd. (IGIM) on behalf of iProfile Canadian Equity Private Pool and any future mutual funds managed by IGIM (collectively referred to as the Top Funds) from certain provisions of National Instrument 81-102 Investment Funds (NI 81-102). This exemption allows the Top Funds to invest in securities of Northleaf IG Canadian PE Holdings (Underlying Northleaf Fund), a non-redeemable investment fund that is not a reporting issuer and is not subject to NI 81-102.
The exemption is based on the following key points:
1. IGIM is a registered corporation in good standing with securities legislation across Canadian jurisdictions.
2. The Top Funds are mutual funds governed by Canadian laws and distribute securities under a simplified prospectus.
3. The Underlying Northleaf Fund, managed by Northleaf Capital Partners, provides access to Canadian private equity assets and is not a reporting issuer or subject to NI 81-102.
4. The Top Funds will be the sole investors in the Underlying Northleaf Fund, which will be considered an illiquid asset under NI 81-102.
5. IGIM believes that investing in private equity through the Underlying Northleaf Fund offers diversification and potential for improved risk-adjusted returns for the Top Funds.
6. The Underlying Northleaf Fund’s investments will be valued quarterly, and its financial statements will be audited annually.
The exemption is conditional upon the following:
1. The Top Funds will not actively participate in the operations of the Underlying Northleaf Fund.
2. No sales or redemption fees will be associated with the Top Funds’ investment in the Underlying Northleaf Fund.
3. No management or incentive fees will be duplicated for services provided to the Underlying Northleaf Fund.
4. Investments in the Underlying Northleaf Fund will be disclosed in the Top Funds’ reports and prospectus.
5. The relationship between IGIM, Northleaf, and Mackenzie will be disclosed in the Top Funds’ prospectus.
6. IGIM and the Independent Review Committee (IRC) will comply with conflict of interest requirements under NI 81-107.
The decision was made by the Manitoba Securities Commission as the principal regulator and is also recognized by the securities regulatory authority in Ontario. The exemption is subject to the test set out in the Legislation for the Decision Maker to make the decision.