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First, the Panel was concerned that the fragmented structure, requiring decisions to be coordinated across up to 13 jurisdictions, makes it difficult for Canadian securities regulators to react quickly and decisively to capital market events.
One illustration of this difficulty was the adoption in September 2008 by some of Canada ’ s international counterparts, including the United States and United Kingdom, of restrictions of short-selling of certain stock as a temporary stability measure.
The Canadian response lagged behind the coordinated efforts of the United States and the United Kingdom, and was not uniform across the provinces.
A second illustration was the delay between the freezing of the non-bank Asset Backed Commercial Paper ( ABCP ) market in August 2007 and the release of a consultation paper by the Canadian Securities Administrators to seek input on a number of proposals that aim to prevent similar capital market failures in the future.
The Panel found that the fragmented Canadian securities regulatory structure is prone to foster slow securities regulatory responses, which makes Canada vulnerable to market and reputational risks.

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