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 specified investment and non-investment funds. This decision, applicable across multiple Canadian jurisdictions, permits these trades under conditions ensuring alignment with investment objectives, proper valuation, and independent review. The exemption addresses the unavailability of market prices for these securities, thus facilitating efficient fund management. The decision is underpinned by National Instrument 31-103 and National Instrument 81-107, with compliance requirements including IRC approval and detailed record-keeping.