On April 17, 2025, the Canadian Securities Administrators (CSA) published final amendments to National Instrument 81-102 Investment Funds. These amendments in particular cut RIIIFs, which in Ontario are known as Public Crypto Asset Funds. These funds intentionally invest directly or indirectly in crypto assets. We think that the CSA’s goal of encouraging innovation while maintaining a robust investor protection within the investment fund regulatory regime is laudable.

The CSA is made up of the securities regulators of each of Canada’s provinces and territories. It’s an often underappreciated player in coordinating and harmonizing regulations across the Canadian capital markets. These amendments would enhance regulatory clarity for Public Crypto Asset Funds navigating this rapidly evolving space.

The updated regulations outline specific criteria regarding the types of crypto assets that Public Crypto Asset Funds can purchase and hold. Each of the 3 amendments place strict limitations on investments in crypto assets. Similar impact Public Crypto Asset Funds Face this Same Impact Other Reporting Issuer Investment Fund

Perhaps the brightest spotlight on the amendments shines on the care of crypto assets held in custodian accounts on behalf of the fund. Public Crypto Asset Funds are now subject to new requirements specifically tailored to protect these vulnerable assets. The CSA hopes to create a clear, consistent framework for Public Crypto Asset Funds with these steps.

"Canadian securities regulators are committed to enhancing investor protections and supporting the stability and strength of our capital markets," said Stan Magidson, CSA Chair and Chair and CEO of the Alberta Securities Commission.

These amendments reflect the CSA's ongoing efforts to appropriately regulate the crypto asset market, striking a balance between fostering innovation and protecting investors.