The Canadian Securities Administrators have issued a notice outlining the circumstances in which they will support applications for relief from the requirements to file insider reports by people who are only superficially vice presidents.

The note seeks to offer relief to people who are technically insiders by virtue of holding the title of “vice president” but who do not have access to confidential inside information. When the insider reporting requirements were developed in the 1960s, VPs exercised a senior officer function and were therefore required to file insider reports.

“Since that time, we recognize that it has become widespread industry practice, particularly in the financial services sector, for issuers to grant the title of ‘vice-president’ to certain employees primarily for marketing purposes. In many cases, these individuals do not ordinarily have access to material undisclosed information prior to general disclosure and would not reasonably be considered to be senior officers from a functional point of view,” it says.

The CSA says that it recognizes that requiring all vice presidents to file insider reports may impose significant regulatory costs on these individuals and their issuers for little or no corresponding benefit. It says, CSA staff will generally support an application for relief from the insider reporting requirements for an individual who is a “nominal vice-president” under certain guidelines.