CALU submission on Proposed Notifiable Transaction Rules recommending that the exclusion provided to financial institutions under draft subsection 237.4(6) not be part of the final notifiable transaction legislation. This would ensure these financial institutions play a similar role in reporting to the CRA, as compared to other financial and advisory organizations, by ensuring that proper reporting is being provided by the employer in respect any advisory services provided by their employees that relate to a notifiable transaction. Alternatively, the exclusion in draft subsection 237.4(6) should be extended to all employees of these financial institutions, subject to the same limitations set out in draft subsection 237.4(7).

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