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Trans-Canada Capital Inc. and TCC Alphabet Master Fund, LP

2021-06-28 | Decision | 81-106 | Investment funds and structured products | https://www.osc.ca/en/securities-law/orders-rulings-decisions/trans-canada-capital-inc-and-tcc-alphabet-master-fund-lp

National Instrument 81-106 Investment Fund Continuous Disclosure, ss. 2.2, 5.1(2)(a) and 17.1.


The Securities Commission has granted a 90-day extension to a mutual fund, which is not a reporting issuer, for filing and delivering its annual financial statements. The fund, managed by Trans-Canada Capital Inc. (TCC), faced difficulties meeting the original 90-day deadline due to its investments in underlying funds with varying financial year-ends and reporting deadlines. Consequently, the fund could not complete its financial statements in time without the audited statements of these underlying funds.

Under National Instrument 81-106 Investment Fund Continuous Disclosure (NI 81-106), the fund was required to file and deliver its audited annual financial statements within 90 days after its financial year-end (December 31). However, the fund was unable to meet this deadline and applied for an exemption.

The Commission’s decision allows the fund to extend its annual filing and delivery deadlines to June 30 each year, provided certain conditions are met. These conditions include the fund’s investment strategy, the timing of investments in underlying funds, notification to the fund’s securityholder, and disclosure amendments in the offering memorandum if new investors are acquired. The relief is subject to the fund’s compliance with the extended deadline and will expire within one year of any relevant regulatory changes that affect the filing and delivery requirements for mutual funds.