Many registrants received a reminder earlier this month from the securities regulatory authorities that the enhanced cost disclosure reporting requirements for investment funds (and new cost and performance reporting guidance for segregated funds) will be in force on January 1, 2026. The changes to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations increase obligations relating to the existing annual report on charges and other compensation, which are provided to clients, in order to include costs related to investment funds (known as the total cost reporting, or TCR, requirements). As a result, the first annual reports with the new required information will be due for the year ended December 31, 2026. While the deadline is not imminent, much work is required by the industry to ensure that the requisite information is available, and the regulators have stated they do not intend to grant any extensions. If you are a registered adviser, dealer or investment fund manager with questions or looking for more information on these requirements, please contact your usual lawyer at AUM Law.
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