The Ontario Securities Commission granted Sun Life Capital Management (Canada) Inc. (the Filer) an exemption from certain restrictions under National Instrument 31-103, allowing inter-fund trades of private debt securities and mortgages between specific investment and non-investment funds. This decision is based on the Filer’s representations and is subject to several conditions, including adherence to valuation procedures, independent review committee (IRC) approval, and detailed record-keeping. The exemption aims to provide liquidity and access to investments that might not be available in the market, ensuring that transactions are in the best interest of the funds involved. The decision also requires disclosure to investors about the nature and valuation of these transactions. Relevant regulations include NI 31-103, NI 81-107, and NP 29.