Companion Policy to NI 81-102 Investment Funds
Part 15 Securityholder Records
Section 15.1

Securityholder Records

(1) section 18.1of the instrument requires the maintenance of securityholder records, including past records, relating to the issue and redemption of securities and distributions of the investment fund. section18.1of the instrument does not require that these records need be held indefinitely. It is up to the particular investment fund, having regard to prudent business practice and any applicable statutory limitation periods, to decide how long it wishes to retain old records.

(2) The Canadian securities regulatory authorities are of the view that the requirements in