Torys LLP says that proposed new continuous disclosure rules for investment funds promise some significant changes.

In a new memo to clients, Torys says that for one, the proposed rule would apply to exchange-traded funds and closed funds, and in some provinces private pooled funds. Torys says that this is a big change for funds that had previously been treated as regular issuers.

The rules impose specific content requirements on funds’ financial statements, including reporting the current market value of their assets. Torys says that the disclosure of the portfolio’s market value is a big change for non-redeemable investment funds, although labour-sponsored funds and venture capital funds may get some relief from this requirement. On the upside, mutual funds would only be required to deliver their financials to investors who want them.

Funds will also be required to develop policies governing their proxy voting practices, and to disclose their voting records to investors on request. Torys notes that this measure may have “significant systems and compliance implications” for funds.