OSC regulatory fee overhaul draws sharp pushback from SIMA

Multiple fee increases

According to SIMA’s submission, which cites OSC financial statements for the period ending March 31, 2025, market participant fees increased 66.6 per cent between 2016 and 2025 — approximately $58.9 million — representing a compound annual growth rate of about 5.4 per cent. That rate is nearly double Ontario’s average CPI over the same period, which was approximately 2.7 per cent.

“We support the OSC’s efforts to promote capital formation and growth for all market participants,” said Andy Mitchell, SIMA’s President and Chief Executive Officer. “At the same time, we urge any amendments to be considered within the context of multiple fee increases and the existing fee models across the broader regulatory environment.”

SIMA further warned that the proposed highest fee tier — which would impose substantially higher costs on the largest market participants — has not been accompanied by sufficient justification, particularly regarding the OSC’s assertion that those firms generate proportionately greater regulatory intensity.

Calls for structural reform across the CSA

Beyond opposing specific provisions, SIMA’s submission puts forward a broader reform agenda for the Canadian Securities Administrators (CSA) as a whole. The association is calling for multi-year fee frameworks that give firms the predictability they need for financial planning, greater transparency in how reserves and surpluses are managed, and full disclosure of segmented cost data by OSC branch.

SIMA also recommends that the OSC reconsider how it calculates participation fees for investment dealers, specifically arguing that financing costs on secured financing transactions — such as repos and securities borrowing and lending — should be deductible from gross revenue when determining market participation fees. The association contends that gross capital markets revenue overstates a firm’s true capacity to pay and does not accurately reflect the regulatory burden imposed.

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