An investment fund manager (IFM) is launching a new alternative investment fund that will be offered to accredited investors across multiple provinces. The IFM has diligently prepared the offering memorandum and subscription agreements. Beyond these documents, what critical step must the IFM take concerning provincial regulators, specifically related to the fund's offering in jurisdictions where they don't have a head office, to ensure compliance with the harmonized regulatory framework overseen by the Canadian Securities Administrators (CSA)?

Question: An investment fund manager (IFM) is launching a new alternative investment fund that will be offered to accredited investors across multiple provinces. The IFM has diligently prepared the offering memorandum and subscription agreements. Beyond these documents, what critical step must the IFM take concerning provincial regulators, specifically related to the fund's offering in jurisdictions where they don't have a head office, to ensure compliance with the harmonized regulatory framework overseen by the Canadian Securities Administrators (CSA)?

Answer options:

• Register the offering memorandum with each provincial securities commission.
• Obtain a no-action letter from the principal regulator of each province. ✅ File a Form 13-101F1 - System for Electronic Document Analysis and Retrieval (SEDAR+) filing to the principal regulator, with copies sent to non-principal regulators.
• Seek specific product approvals from CIRO for the alternative investment fund before soliciting investors.

Correct answer: File a Form 13-101F1 - System for Electronic Document Analysis and Retrieval (SEDAR+) filing to the principal regulator, with copies sent to non-principal regulators.

Explanation: Under the National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions and the SEDAR+ system, an IFM launching an exempt offering files a Form 13-101F1 (and related offering documents) with their principal regulator (where their head office is located). This filing is then made available to other 'non-principal' provincial regulators through SEDAR+, fulfilling cross-jurisdictional filing requirements under the CSA's harmonized system.