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Insider Profile – Duplicate Insider Profile

Requirements

You need to file one insider profile and indicate the names of all the companies of which you are an insider. If you use an agent to file for you, it is recommended that you only use one. However, if you choose to have different people file insider reports for you for these different companies, you must make sure that only one insider profile is created for you.

 

If you have a duplicate insider profile, you are required to choose one profile that will continue to be used going forward, ensuring that you have the correct insider access key associated with that profile. Any transactions filed under the duplicate profile(s) will need to be re-filed under the chosen profile and deleted from the duplicate profile(s).

 

Note: The requirement is that an insider shall not file more than one insider profile on SEDI. Refer to section 2.1(4) of the PDF version of NI 55-102 dated May 9, 2003.

How to Correct a Duplicate Insider Profile

Steps to correct a duplicate insider profile follow:

Step

Action

1

In advance of any corrections, please contact the Securities Commission that is the principal regulator for the issuer to advise them that you are correcting a duplicate insider profile.

 

You will be provided with an insider profile deletion request form to be signed by the insider and faxed back to the principal regulator. The principal regulator will also advise you of the appropriate steps to follow to correct the current profile and delete the duplicate profile. The general approach is described here.

 

It is important to coordinate the timing of the re-filed transactions with the principal regulator so that applicable transactions are not treated as late filings when filed under the remaining (current) insider profile.  

2

Record any transactions which are currently under the duplicate profile to the current profile. In some cases, you may need to add issuers from the duplicate profile to the current insider profile in order to re-file the transactions. The current insider profile and re-filed insider reports will consolidate the same details previously recorded in the duplicate profile(s) and its corresponding insider reports.

 

Include General Remarks (maximum number of characters for remarks: 254) in the re-filed transactions to indicate that the filings are being made to delete a duplicate insider profile so the public understands why the filings may appear late under the current profile. It is suggested that you include the duplicate insider profile number in the remarks as well.

 

Note: You may find it helpful to print the insider transaction detail report from the public filings on SEDI (display the general remarks) to review the transactions filed under the duplicate profile prior to re-filing.

 

After the transactions are re-filed, you may find it useful to print the insider transaction detail report for the current profile to confirm that all transactions were successfully re-filed.

3

Delete all transactions posted under the duplicate insider profile(s) after they have been re-filed in the current insider profile. It is recommended that insiders or agents take responsibility for deleting their own transactions as they are obligated to ensure that each report was successfully re-filed prior to deletion.

 

The securities regulators may request the SEDI Operator to delete the transactions, when removing the duplicate insider profile, in the following circumstances.

  • the insider cannot access/amend the insider reports to delete them because the insider recorded a ceased to be insider date for the issuer in the duplicate insider profile

  • an agent created the duplicate insider profile and the insider does not have the access key

  •  at the discretion of the principal regulator

4

Contact the principal regulator to request the deletion of the duplicate profile.

Contact Information

Click here for a list of provincial and territorial securities regulators.

Related Documents to add an issuer or re-file transactions

Insider Profile – Add or Amend Issuer Information Including Ceased to be an Insider

File an Opening Balance on an Initial Report

File an Insider Report for Common Shares

Preliminary Information for Stock Options Filings

Insider Report for Stock Options

To Delete a report

Click here for instructions to delete an insider report.