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Uniquely Canadian Regulatory Expectations For Investment Fund Liquidity Risk Management – Finance and Banking – Canada – Mondaq News Alerts



On September 18, 2020, the Canadian Securities Administrators
(CSA) released CSA Staff Notice 81-333 Guidance on Effective
Liquidity Risk Management for Investment Funds
. The Notice
provides guidance for investment fund managers (IFMs) and portfolio
managers (PMs) on the CSA’s expectations that those firms
develop and maintain effective liquidity risk management (LRM)
frameworks in respect of the investment funds they manage. An LRM
framework supports the ability of investment funds to satisfy
redemption requests without significantly diluting remaining fund
investors and maintain the funds’ liquidity profiles. The
guidance provided in the Notice is aimed at IFMs of investment
funds that are subject to National Instrument 81-102 Investment
, although the CSA note that many of the LRM practices
and examples contained in the Notice may also be relevant for other
types of investment funds.


Through the Notice, the CSA respond to international initiatives
over a number of years relating to LRM practices from the Financial
Stability Board (FSB) and the International Organization of
Securities Commissions (IOSCO)1. These initiatives took
into account lessons learned from the financial crisis of 2007 with
an initial focus on LRM of open-ended collective investment
schemes. IOSCO’s 2018 Recommendations for Liquidity Risk
Management for Collective Investment Schemes – Final
, prompted the two Canadian participants in IOSCO
– L’Autorité des marchés financiers (AMF)
and the Ontario Securities Commission (OSC) – to seek input
from various Canadian market participants in responding to
IOSCO’s recommendations and developing the principles set out
in the Notice2.

No “one size fits all”

Liquidity risk refers to “the risk that a fund is unable to
satisfy redemption requests without having a material impact on the
remaining securityholders of a fund” (ie. the potential
mismatch between the liquidity of underlying portfolio assets of
the investment fund and the redemption terms and conditions
afforded to fund investors). The CSA emphasize that materiality
varies between funds and that different approaches to effectively
manage liquidity risk can be used according to a fund’s
characteristics such as size, structure, investment objectives and
strategies and investor base. The CSA expressly state that the
guidance does not suggest or endorse a “one size fits
all” approach to LRM, given that each investment fund has its
own unique characteristics, including liquidity risk. This will be
welcome news particularly for smaller managers.

CSA expectations and existing regulatory requirements

While the Notice is intended as guidance for IFMs and PMs, it is
clear from the language used that the CSA’s expectations will
be used as a reference point in their future compliance reviews of
LRM policies and procedures, as well as fund disclosure.

The CSA expects each IFM to establish and maintain an effective
LRM framework that is consistent with its statutory standard of
care, as well as its obligations, as applicable, under National
Instrument 31-103 and NI 81-102. By linking a fund’s liquidity
risk with the “business of the fund” and the internal
control and compliance requirements contained in NI 31-103, the CSA
highlight that registrant firms have an obligation to establish LRM
controls and supervision sufficient to manage the liquidity risks
associated with their funds.

The Notice reiterates the CSA’s views that managers of
investment funds subject to NI 81-102 must establish an effective
LRM policy that considers the liquidity of the types of assets in
which the investment fund will be invested and the fund’s
obligations and other liabilities. IFMs should regularly measure,
monitor and manage the liquidity of the investment fund’s
underlying portfolio assets, keeping in mind the time to liquidate
each portfolio asset, the price at which the asset may be sold and
the pattern of redemption requests.3

LRM framework

The CSA highlight five important key areas for an effective LRM

1. Strong and effective governance

IFMs should assess whether an existing governance body or new
committee needs to be established in order to provide adequate
oversight of the LRM function. Such assessment should consider
whether new or enhanced reporting and other compliance mechanisms
need to be implemented to ensure the necessary information is being
monitored and shared with relevant parties.

The CSA set out potential responsibilities of such an oversight
committee, including reporting and escalation procedures,
valuation, conflicts of interest, ongoing review of LRM policies
and procedures as well as establishing stress testing and reviewing
the results of such stress testing.

2. Creation and ongoing maintenance of LRM procedures

An LRM process should begin with the design phase of investment
products to ensure alignment of redemption terms and investment
strategy taking into consideration the lifecycle of the fund. An
effective LRM process may include the regular assessment of the
liquidity profile of the fund’s assets and liabilities taking
into consideration current market conditions, redemption activity,
and investor behaviour and periodic communication and review by
senior management and/or relevant personnel. A number of principles
and practical implementation strategies are set out in the Notice,

  • Aligning investment objectives,
    strategies and the redemption policy of a fund with the liquidity
    profile of its underlying portfolio assets and redemption demands
    of the investor. For example, in cases where the fund holds
    substantial amounts of thinly traded securities, or whose
    securities have longer settlement periods, an IFM could elect to
    have the fund offer less frequent redemption opportunities to
  • Performing active, ongoing portfolio
    monitoring using qualitative and quantitative metrics to ensure
    adequate levels of liquidity exist to meet redemption needs and
    other obligations; and
  • Setting internal liquidity thresholds
    and targets that management can use to assess the liquidity profile
    of a fund and make any necessary adjustments.

3. Stress testing

The CSA explain that stress testing may be an effective aspect
of an IFM’s LRM process, given that it will enable an IFM to
assess and respond to liquidity risks. Some of the key factors for
stress testing include:

  • Identification of risks including
    market and redemption risks such as market stress affecting a class
    or subclass of asset, interest rate risk, geopolitical risk;
  • Scenario analyses that are diverse
    and reflect material risks relevant to the fund. IFMs may consider
    factors such as a downgrade of the credit rating of an underlying
    portfolio asset or of the related issuer, changes in interest
    rates, widening of bid-ask spreads and economic shocks;
  • Historical stress testing that
    include factors such as the comparison of historical cash flows
    with industry-wide cash flows for funds of similar size and
    strategy, or the redemption activity of the largest investor or
    group of investors; and
  • Hypothetical stress testing which
    attempts to measure the potential impact of an event that has not
    yet occurred, such as interest rate changes or the potential for
    counterparty default.

Frequency of stress testing will depend on the specific
attributes of a fund such as fund size, redemption frequency and
investor base. It will be important to document and analyse testing
results and communicate the results to the committee overseeing
liquidity risk.

4. Disclosure of liquidity risks

The CSA consider that disclosure of material liquidity risk is
part of full, true and plain disclosure required to be made to
investors in an investment fund. The existing disclosure
requirements of National Instrument 81-101 provide for specified
mandated disclosure of liquidity risk for public investment funds,
including the risk that redemptions may be suspended and the
specific risks associated with redemptions by holders of large
positions in the funds. The CSA expect that LRM governance matters
relating to the funds will be included in the prospectus disclosure
and if an IFM does not have written policies and procedures around
LRM, this fact should then be disclosed to investors. The Notice
gives examples of the CSA’s expectations for such disclosure
that IFMs should review in connection with prospectus filings and

Liquidity risks should also be addressed in a fund’s
continuous disclosure documents, including the management reports
of fund performance mandated by National Instrument 81-106. This
would include disclosure of any liquidity challenge during the
period and how those challenges were addressed, along with changes
in risk level of a fund due to market conditions, significant
redemptions or liquidity of underlying portfolio assets.

5. Use of LRM tools to manage potential and actual liquidity

Any use of LRM tools (such as suspension of redemptions and
borrowing) to aid in the liquidity management of a fund are subject
to certain overarching principles:

  • The use of a mechanism that affects
    redemption rights is only justified in open-ended funds in
    exceptional circumstances. Such circumstances are rare, such as
    where a fair and robust valuation of the assets in which the fund
    is invested is difficult or impossible to carry out, or where
    redemption demands are so large/exceptional that liquidity cannot
    be raised in the timeframe required to meet the demands.
  • The use of extraordinary LRM tools
    must be in the best interest of the fund investors collectively. A
    fund should only use such tools when it is in the best interest of
    investors and when the fair and equal treatment of incoming,
    ongoing and outgoing investors is maintained.

The CSA guidance contained in the Notice provides a uniquely
Canadian flexible response to IOSCO’s 2018 recommendations for
liquidity risk management of collective investment schemes, among
other international developments. The Notice will serve as a useful
checklist for IFMs and PMs to establish and evaluate their LRM
polices and procedures having regard to the nature of their funds.
The guidance should be applied to investment funds that are subject
to NI 81-102; however, we expect the CSA will also consider that
managers of private pooled funds and other commingled vehicles
should apply these principles.


1.  IOSCO, Principles of Liquidity Risk Management
for Collective Investment Schemes
, Final Report, Report of the
Board of IOSCO, March 2013
. FSB, Policy Recommendations to
Address Structural Vulnerabilities from Asset Management
, 2017. IOSCO, Recommendations for Liquidity
Risk Management for Collective Investment Schemes – Final
, 2018; and IOSCO, Open-Ended Fund Liquidity and
Risk Management – Good Practices and Issues for
, 2018.

2.  Including a Task Force struck by The Investment
Funds Institute of Canada to survey its mutual fund manager members
between October and December, 2018. The mandate of the Task Force
was to identify questions that would survey investment fund
managers on their policies and procedures for managing portfolio
liquidity risk.

3.  See also OSC Staff Notice 81-727 Report on
Staff’s Continuous Disclosure Review of Mutual Fund Practices
Relating to Portfolio Liquidity

About BLG

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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Manulife Investment Management Launches Five Smart Exchange-Traded Funds – Canada NewsWire



C$ unless otherwise stated      

TORONTO, Nov. 25, 2020 /CNW/ – Manulife Investment Management announced five new Smart Exchange-Traded Funds (ETFs) have closed their initial offering of units and will begin trading on the Toronto Stock Exchange today. The three Canadian fixed income ETFs and two equity ETFs will provide investors with the opportunity to access the growing popularity of the ETF structure while taking advantage of Manulife’s investment expertise with active quantitative strategies.

Manulife Smart Dividend ETF and Manulife Smart U.S. Dividend ETF are tailored for Canadian investors looking for income producing investments that can provide a steady cash flow stream. They seek to provide a steady flow of income and long-term capital appreciation by investing in a diversified portfolio of dividend paying securities.

Manulife Smart Short-Term Bond ETF, Manulife Smart Core Bond ETF and Manulife Smart Corporate Bond ETF aim to support investors looking to generate steady income in their investment. They seek to earn the highest level of income consistent with the preservation of capital by investing in a diversified portfolio of fixed income securities.

“Manulife Investment Management’s new exchange-traded funds have an attractive price point within their respective categories, which offer a good balance between price and the potential to outperform,” said Bernard Letendre, Head of Wealth and Asset Management, Canada. “Adding these new Manulife ETFs are part of our commitment to investors to provide them with the most amount of value.”

ETF name


Manulife Smart Short-Term Bond ETF


Manulife Smart Core Bond ETF


Manulife Smart Corporate Bond ETF


Manulife Smart Dividend ETF


Manulife Smart U.S. Dividend ETF

UDIV (hedged)

UDIV.B (unhedged)

Manulife Investment Management is always looking to expand its line up to meet the growing and diverse needs of investors. The new Manulife Smart ETFs showcase our active management capabilities and commitment to offering investors investment options at different price points.

Manulife ETFs are managed by Manulife Investment Management Limited (formerly named Manulife Asset Management Limited). Manulife Investment Management is a trade name of Manulife Investment Management Limited. Commissions, management fees and expenses all may be associated with exchange traded funds (ETFs). Investment objectives, risks, fees, expenses and other important information are contained in the ETF Facts as well as the prospectus, please read before investing. ETFs are not guaranteed, their values change frequently, and past performance may not be repeated.

About Manulife Investment Management

Manulife Investment Management is the global wealth and asset management segment of Manulife Financial Corporation. We draw on more than a century of financial stewardship and the full resources of our parent company to serve individuals, institutions, and retirement plan members worldwide. Headquartered in Toronto, our leading capabilities in public and private markets are strengthened by an investment footprint that spans 17 countries and territories. We complement these capabilities by providing access to a network of unaffiliated asset managers from around the world. We’re committed to investing responsibly across our businesses. We develop innovative global frameworks for sustainable investing, collaboratively engage with companies in our securities portfolios, and maintain a high standard of stewardship where we own and operate assets, and we believe in supporting financial well-being through our workplace retirement plans. Today, plan sponsors around the world rely on our retirement plan administration and investment expertise to help their employees plan for, save for, and live a better retirement. 

As of September 30, 2020, Manulife Investment Management had CAD$923 billion (US$692 billion) in assets under management and administration. Not all offerings are available in all jurisdictions. For additional information, please visit

About Manulife

Manulife Financial Corporation is a leading international financial services group that helps people make their decisions easier and lives better. With our global headquarters in Toronto, Canada, we operate as Manulife across our offices in Canada, Asia, and Europe, and primarily as John Hancock in the United States. We provide financial advice, insurance, and wealth and asset management solutions for individuals, groups and institutions. At the end of 2019, we had more than 35,000 employees, over 98,000 agents, and thousands of distribution partners, serving almost 30 million customers. As of September 30, 2020, we had $1.3 trillion (US$943 billion) in assets under management and administration, and in the previous 12 months we made $31.2 billion in payments to our customers. Our principal operations are in Asia, Canada and the United States where we have served customers for more than 155 years. We trade as ‘MFC’ on the Toronto, New York, and the Philippine stock exchanges and under ‘945’ in Hong Kong.

SOURCE Manulife Investment Management

For further information: Media Contact, Olivia Jones, Manulife, 438-340-3416, [email protected]

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Council varies its investment policy – BC Local News – BCLocalNews



The District of Houston has bolstered its policy of placing public monies in local financial institutions by allowing the amount to be invested to exceed othwerwise specified limits.

It means that $7.5 million in investments coming due Dec. 31 can be placed with either the Bulkley Valley Credit Union or the Royal Bank or with both and not placed elsewhere.

In a detailed presentation made to council Nov. 17, District of Houston chief administrative officer Gerald Pinchbeck, also the District’s financial officer, noted the District’s existing policy sets dollar amount limits based on a percentage of the District’s total investment account and on a percentage of the assets of the Bulkley Valley Credit Union.

The same policy also sets limits on what can be invested with the Royal Bank, the only other financial institution in the community, based on the percentage of securities within the District’s total investment portfolio.

“If there are any overages, then upon maturity the investments woud need to be made elsewhere,” he said.

The District’s investment mix includes term deposits now at the credit union which are guaranteed and senior government and corporate bonds.

In approving of the move to exceed the investment limits in the policy, council directed that the policy be brought back for a further review at a future date.

“Investments under the temporary policy variance will be made by reviewing the rates being offered, the security of the investments available, and the expected return on investment,” said Pinchbeck.

The money the District invests are not required for its current operating or capital spending obligations.

The District’s long-standing policy of placing investments with financial institutions that have a presence in the community reflects its commitment to recognize and support local businesses.

Houston Today

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Feedback Isn’t Just A Gift-It’s An Investment – Forbes



It’s often said that feedback is a gift. But the truth is—feedback is an investment.

A colleague and I recently received feedback from a client about a session we had facilitated that did not meet their expectations. The client reported that participants were not adequately engaged by the content and that we didn’t leave enough room for discussion. They even complained about our choice of closing music. (I guess not everyone appreciates Kelly Clarkson.)  The feedback was thoughtfully delivered, but it still hit hard. I took a few deep breaths, thanked the client and discussed how to improve the next session. My colleague and I incorporated the feedback into our next workshop plan, and they loved it. Their critical feedback was key to our success. 

If someone cares enough about you to give you feedback, it is a sign that they care about the relationship. Our client was able to deliver important critical feedback to us because we had built a foundation of trust. We had been working with them for more than a year, conducting workshops, having frequent calls, getting to know one another as professionals and as human beings. We had also invested in the relationship in big and small ways. This meant that when we stumbled, our client did not see us as just another vendor who could be easily replaced. Instead, they came to us and shared their concerns. And though the feedback was a bit painful, it helped us grow and strengthen the relationship. 

For many people, the investment of giving critical feedback feels risky.  A 2017 study of managers, whose job it is to give feedback, found that 44% report discomfort giving negative feedback and 21% avoid it. Why? In my experience conducting feedback trainings, many professionals express fear that they will encounter defensiveness, worry that the feedback will damage the relationship, and hopelessness about people’s ability to change. These perceived risks are a lot to overcome.

So if someone who is not required to give you feedback takes the risk of offering you what Warren Buffet calls the “very expensive gift” of honesty and gives you critical feedback, they are signaling that (1) the issue matters to them, (2) the relationship matters to them, and (3) they believe—or at least hope—that improvement is possible. That is good news.

Getting critical feedback stings. When someone tells you that something you did harmed them or bugged them or didn’t work for them, it is natural to feel embarrassed, hurt or defensive. But there is something even worse than getting critical feedback about a blind spot: when someone withholds important feedback, denying you the opportunity to learn, improve and repair. So the next time someone gives you critical feedback, even if it stings, remember that it signals that they are investing some of their personal capital in you. Really listen with curiosity. How can you make their investment pay off for both of you?

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