Securities Law & Instruments

Headnote

Item F(1) of Appendix C of OSC Rule 13-502 Fees -- exemption for Funds from paying an activity fee of $5,500 in connection with an application brought under subsection 147 of the Act, provided an activity fee be paid on the basis that the application be treated as an application for other regulatory relief under item F(3) of Appendix C of the Rule.

Rules Cited

OSC Rule 13-502, Fees (2003) 26 OSCB 4339 and 27 OSCB 7747.

Securities Act, R.S.O. 1990, c. s.5 as am., s. 147.

July 15, 2005

McCarthy Tetrault LLP
Box 48, Suite 4700
Toronto Dominion Bank Tower
Toronto, Ontario
M5K 1E6

Attention: Katarzyna Szybiak

Dear Sirs and Mesdames:

Re:
CI Investments Inc. and the Funds
Application under Section 6.1 of OSC Rule 13-502 - Fees ("Rule 13-502")
Application # 48805

By letter dated June 10, 2005 (the "Application"), you applied on behalf of CI Investments Inc. ("CI"), the manager and trustee of the CI Funds and the Clarica Funds (as defined in the Application) (collectively, the "Funds"), to the Canadian securities regulatory authorities under section 147 of the Securities Act (Ontario) (the "Act") for an extension of the time limits pertaining to the distribution of securities under the simplified prospectus and annual information form of the CI Funds dated July 23, 2004, as amended from time to time, (collectively, the "CI Prospectus") and under the simplified prospectus and annual information form of the Clarica Funds dated July 15, 2004, as amended from time to time (collectively, the "Clarica Prospectus").

By letter dated July 11, 2005 (the "Fee Application"), you additionally applied to the Director on behalf of CI for the following:

(i) an exemption, pursuant to subsection 6.1 of Rule 13-502 (the "Fee Exemption"), from the requirement to pay an activity fee of $5,500 in connection with the Application in accordance with item F(1) of Appendix C of Rule 13-502, on the condition that fees be paid on the basis that the Application be treated as an application for other regulatory relief under item F(3) of Appendix C of Rule 13-502; and

(ii) an exemption from the requirement to pay an activity fee of $1,500 in connection with the Fee Exemption application.

From our review of the Application, the Fee Application and other information communicated to staff, we understand the relevant facts and representations to be as follows:

1. Each Fund is a reporting issuer in each of the provinces and territories of Canada (the "Jurisdictions") and is not in default of any filing requirements under the securities legislation of any of the Jurisdictions.

2. The securities of the CI Funds are qualified for distribution in each of the Jurisdictions by means of the CI Prospectus that was prepared and filed in accordance with Canadian securities regulatory requirements.

3. The securities of the Clarica Funds are qualified for distribution in each of the Jurisdictions by means of the Clarica Prospectus that was prepared and filed in accordance with Canadian securities regulatory requirements.

4. The lapse date of the CI Prospectus is July 23, 2005, however, the CI Funds are expected to be merged on or about July 30, 2005 (the "Effective Date").

5. The lapse date of the Clarica Prospectus is July 15, 2005, however, the Clarica Funds are expected to be merged on the Effective Date.

6. In the Application, CI requested under section 147 of the Act an extension of the time limits pertaining to the distribution of the securities under the CI Prospectus and the Clarica Prospectus. Item F(1) of Appendix C of Rule 13-502 specifies that applications under section 147 of the Act pay an activity fee of $5,500.

7. If CI were renewing the CI Prospectus or the Clarica Prospectus, rather than merging the Funds, it could have sought an extension of the lapse date applicable to the CI Prospectus or the Clarica Prospectus pursuant to subsection 62(5) of the Act. The activity fee for such an application would be $1,500 in accordance with item F(3) of Appendix C of Rule 13-502.

Decision

This letter confirms that, based on the information provided in the Application, the Fee Application and the facts and representations above, and for the purposes described in the Fee Application, the Director hereby exempts CI and the Funds from:

(a) paying an activity fee of $5,500 in connection with the Application, provided that the Funds pay an activity fee on the basis that the Application be treated as an application for other regulatory relief under item F(3) of Appendix C to Rule 13-502; and

(b) paying an activity fee of $1,500 in connection with the Fee Application under item F(3) of Appendix C to Rule 13-502.

Yours truly,

"Leslie Byberg"
Manager, Investment Funds Branch