Saskatchewan securities division releases registration and prospectus exemption for qualified persons entering into OTC derivatives

Margaret Grottenthaler

The Saskatchewan Securities Act, 1988 (the Saskatchewan Act) includes within its definition of "security" a futures contract or option that is not an exchange contract. Given the wording of the definition, there has been uncertainty as to whether OTC forwards and other OTC derivatives transactions would fall within this category and consequently be subject to the registration and prospectus requirements of the Saskatchewan Act. The issue has now been addressed by the Saskatchewan Financial Services Commission, Securities Division. On November 26, 2009, it issued General Order 91-907 exempting over-the-counter (OTC) derivatives trading among qualified parties from the registration and prospectus requirements under the Saskatchewan Act. The Companion Policy to the General Order states that the Act's definition of "security" includes futures contracts and options that are not exchange contracts and, thus, parties that currently enter into futures contracts or options are subject to the registration and prospectus requirements of the Saskatchewan Act.

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BCSC provides clarification on when a foreign exchange contract may be a "security"

The British Columbia Securities Commission today published a Companion Policy to Blanket Order 91-502 Short Term Foreign Exchange Transactions to clarify when a foreign exchange contract may be considered a "security" for the purposes of the British Columbia Securities Act.

The Companion Policy states that under s. 1(1) of the Securities Act, the following three components of the definition of "security" could describe a forex contract:

(a) a document, instrument or writing commonly known as a security;

(l) an investment contract;

(n) an instrument that is a futures contract or an option but is not an exchange contract.

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