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DRAFT — For regulatory consultation purposes. Not a final submission. To be reviewed by a licensed Canadian securities lawyer before filing.

APPLICATION FOR ADMISSION TO THE CSA REGULATORY SANDBOX

OSC LaunchPad (Ontario Securities Commission) and AMF FinLab (Autorité des marchés financiers)

Applicant: [Applicant Name], Founder & Chief Executive Officer
Entity: Home for AI Inc. (incorporation pending / in progress)
Registered Address: Montreal, Quebec, Canada
Contact: simpliibarrii@outlook.com
Date: June 29, 2026

SECTION 1 — COVER LETTER

[Applicant Name]
Founder & Chief Executive Officer
Home for AI Inc.
Montreal, Quebec, Canada
simpliibarrii@outlook.com

June 29, 2026

TO:

OSC Innovation Office / LaunchPad
Ontario Securities Commission
20 Queen Street West
Toronto, Ontario M5H 3S8
launchpad@osc.gov.on.ca

AND:

AMF FinLab
Autorité des marchés financiers
800, square Victoria
Montréal, Quebec H4Z 1G3
finlab@lautorite.qc.ca

Dear OSC LaunchPad and AMF FinLab,

Re: Application for Dual Admission — OSC LaunchPad and AMF FinLab — Home for AI Inc.

I write on behalf of Home for AI Inc. ("Home for AI" or the "Company"), an early-stage Canadian fintech company headquartered in Montreal, Quebec, to formally apply for simultaneous admission to the OSC Innovation Office LaunchPad program and the AMF FinLab regulatory sandbox.

Home for AI is developing an AI-powered autonomous trading and copy-trading platform targeting Canadian retail investors. The platform deploys AI agents — powered by a fusion model combining Kimi 2.6 and DeepSeek V3 — to autonomously make trading decisions across equities, cryptocurrency, foreign exchange, government bonds, and commodities. Users may elect to "copy-trade" these AI agents, meaning that the users' brokerage accounts automatically mirror the agents' positions in real time. The platform operator receives a 15% profit-share on copy-trading profits; users retain 85%.

This business model is genuinely novel. The platform engages in activities that appear to trigger registration obligations under National Instrument 31-103 — Registration Requirements, Exemptions and Ongoing Registrant Obligations — yet the platform does not fit neatly into any existing registration category. Specifically:

AI agents acting as sole discretionary decision-makers do not map cleanly to the "portfolio manager" registration category, which presupposes human advisers with individual registration;
Copy trading via AI agents raises unresolved questions under the "business trigger" analysis in NI 31-103 s.1.3;
CSA Staff Notice and Consultation 11-348 (December 5, 2024) acknowledges that AI systems raise novel regulatory questions but does not provide a clear registration pathway for autonomous AI agents acting as primary investment decision-makers; and
The platform proposes to serve Canadian retail investors — not solely accredited investors — which raises the bar for regulatory compliance significantly.

Because of these unresolved questions, and because we are committed to operating within a compliant regulatory framework before scaling, we are seeking the guidance and time-limited relief that the CSA Regulatory Sandbox and OSC LaunchPad exist to provide.

The Company requests:

Admission to both the OSC LaunchPad and AMF FinLab programs concurrently, given that the Company is incorporated in Quebec and intends to serve investors across Canada, including in Ontario;
A time-limited exemption from certain registration requirements under NI 31-103 while operating under sandbox conditions (500-user cap, 24-month term, Canada-only, no crypto derivatives);
Proactive regulatory guidance on the specific legal questions identified in Section 6 of this application; and
A compliance officer consultation with OSC and AMF staff within 30 days of sandbox admission.

We acknowledge that sandbox admission does not constitute regulatory approval of the business model, does not guarantee future registration, and does not exempt the Company from applicable laws not specifically addressed in any relief granted. We are committed to full transparency with regulators throughout the sandbox period.

Note bilingue / Bilingual Note (Français)

La présente demande est soumise simultanément à l'Office de la protection des investisseurs LaunchPad de la Commission des valeurs mobilières de l'Ontario (CVMO) et au Laboratoire FinLab de l'Autorité des marchés financiers (AMF) du Québec. Home for AI Inc. est une entreprise montréalaise développant une plateforme de négociation autonome pilotée par intelligence artificielle et de copie de transactions (copy trading) destinée aux investisseurs de détail canadiens. Compte tenu du caractère inédit de notre modèle d'affaires et des questions réglementaires non résolues liées à l'utilisation d'agents d'IA comme décideurs primaires en matière de placement, nous demandons une orientation réglementaire et une dispense temporaire dans le cadre des programmes bac à sable de la CVMO et de l'AMF. Nous nous engageons à collaborer de façon transparente avec les autorités de réglementation tout au long de la période d'essai.

Respectfully submitted,

[Applicant Name]
Founder & CEO, Home for AI Inc.
simpliibarrii@outlook.com

SECTION 2 — EXECUTIVE SUMMARY

2.1 Platform Description

Home for AI is an AI-powered investment platform that deploys autonomous AI trading agents to manage diversified portfolios across global asset classes and allows Canadian retail investors to copy those agents' trades in real time. The platform is built for accessibility — available on web, iOS, Android, and desktop (via Tauri) — and is designed to democratize access to systematic, algorithm-driven investment strategies previously available only to institutional investors and high-net-worth individuals.

Each AI agent on the platform has a distinct identity (expressed through a cat-emoji avatar), a defined investment style and risk profile, and communicates with users in natural language via text and voice chat. Agents draw on live market data and real-time news sentiment analysis to form trading decisions using a proprietary fusion of the Kimi 2.6 and DeepSeek V3 large language models. Users who elect to copy-trade an agent have their brokerage accounts automatically mirrored to that agent's positions in real time, subject to position-size limits and automatic safety controls.

The platform's revenue model is a 15% profit-share on copy-trading profits earned by users; users retain 85% of all gains. No management fees or subscription fees are charged during the sandbox phase. The platform does not pool client capital — each user's account is their own, held at a regulated custodian.

2.2 Why This Is Innovative and Does Not Fit Existing Rules

The platform sits at the intersection of three regulatory domains — securities regulation, AI governance, and payments/AML compliance — without fitting neatly into any of them.

Portfolio Manager (PM) registration under NI 31-103 applies to a person who, as a regular part of a business, manages the investment portfolio of another person or provides investment advice with a view to managing that portfolio. This category was designed for human advisers exercising discretion on behalf of clients. Home for AI's agents are AI systems — not registered individuals — and the platform does not currently have the infrastructure (Chief Compliance Officer, audited financial statements, errors-and-omissions insurance, and individual advising representatives) required of a registered PM.

Exempt Market Dealer (EMD) registration is not appropriate because the platform trades exchange-listed equities, cryptocurrency spot markets, government bonds, forex, and commodities — not exempt-market securities.

Investment Dealer (ID) registration and CIRO membership is the closest functional analog for a platform that executes trades on behalf of retail investors, but this category requires human-supervised dealing representatives for each client account, and does not contemplate AI agents as the primary order-generation mechanism.

CSA Staff Notice and Consultation 11-348 (December 5, 2024) acknowledges that AI systems are increasingly being deployed in capital markets, but explicitly states that the guidance provided "does not create any new legal requirements" and that existing laws may not fully address autonomous AI trading agents operating as primary decision-makers on retail accounts. This is precisely the regulatory gap for which the CSA Sandbox exists.

2.3 Regulatory Relief and Guidance Sought

The Company seeks the following from the OSC and AMF:

Time-limited exemption from the requirement to register as a Portfolio Manager under NI 31-103 s.25(1) for the duration of the sandbox period (24 months), subject to sandbox conditions;
Clarification on whether AI agents constitute "advising representatives" requiring individual registration under NI 31-103;
Guidance on whether the platform's copy-trading profit-share structure constitutes a "referral arrangement" under NI 31-103 s.13.8;
Guidance on the timing and scope of FINTRAC Money Services Business registration for the crypto components of the platform; and
A compliance consultation with OSC and AMF staff within 30 days of sandbox admission.

2.4 Canadian Investor Protection Measures

The platform has designed its sandbox operations with investor protection as the primary constraint, not an afterthought. Key protections include:

Standalone risk disclosure document presented at onboarding, requiring active acknowledgment;
Copy-trading is opt-in only — users must actively elect to copy an agent, with a 48-hour cooling-off period before the first copy trade activates;
Drawdown kill-switch: copy trading for any agent is automatically paused if that agent's performance declines more than 15% in any rolling 30-day period;
No leverage offered during the sandbox phase;
Position-size limits: no single agent trade may exceed 2% of a user's total portfolio value;
No crypto derivatives during the sandbox phase;
KYC and suitability: identity verification and a suitability questionnaire are required before any copy-trading activity can commence;
Transparent fee disclosure at every material step in the onboarding and trading workflow; and
Human oversight: the Company's operator reviews weekly performance reports and retains the ability to override or pause any agent.

2.5 Proposed Sandbox Terms

Parameter	Proposed Term
Duration	24 months from admission date
Maximum clients	500 users
Geography	Canada only
Asset classes	Equities, crypto (spot only), forex, government bonds, commodities
Excluded activities	Crypto derivatives, margin/leverage, pooled funds
Regulatory reporting	Quarterly reports to OSC and AMF; incident reports within 48 hours
Review checkpoints	Month 6, Month 12, Month 18

SECTION 3 — BUSINESS MODEL DESCRIPTION

3.1 AI Agent Architecture

Home for AI's core technology is a multi-agent AI trading system in which each "agent" is a distinct, stateful AI entity with a defined investment mandate, risk tolerance, and personality. Agents operate continuously during market hours and during extended cryptocurrency trading windows, ingesting live market data, order book feeds, financial news, and macroeconomic indicators to generate trading signals.

Each agent has three functional layers:

Perception Layer: Real-time data ingestion from market data providers (equities tick data, forex feeds, crypto exchange APIs, news sentiment APIs). The agent processes this input to construct a current-state representation of the market environment relevant to its mandate.
Decision Layer: The fusion model (Kimi 2.6 + DeepSeek V3, described below) processes the perception layer's output and generates trade recommendations — including asset, direction (long/short), quantity, timing, and stop-loss/take-profit parameters. Decisions are logged with full explanatory metadata for audit purposes.
Execution Layer: Validated trade signals are transmitted to the platform's order management system, which routes orders to the appropriate exchange or broker via API. Copy-trade orders are generated simultaneously for all users currently mirroring that agent.

Agents do not share capital between users; each user's account is managed independently. The system is designed so that each agent's trade is replicated proportionally to each following user's account based on the user's available capital and the position-size limit (2% maximum per trade).

3.2 Kimi 2.6 + DeepSeek V3 Fusion Model

The platform uses a proprietary ensemble approach combining two state-of-the-art large language models:

Kimi 2.6 (developed by Moonshot AI): A large-scale multimodal reasoning model with strong performance on complex analytical tasks, including financial document analysis and multi-step quantitative reasoning.
DeepSeek V3 (developed by DeepSeek): A mixture-of-experts language model with strong performance on structured data reasoning and code generation, used here for signal generation, quantitative analysis, and order parameter calculation.

The fusion operates as follows: market context data is processed in parallel by both models; their outputs are weighted and combined using a proprietary ensemble layer that has been calibrated on historical market data. Neither model operates as the sole decision-maker; the ensemble architecture is intended to reduce the risk of single-model failure modes.

Important regulatory disclosure: Both Kimi 2.6 and DeepSeek V3 are developed by companies with significant operations in the People's Republic of China (Moonshot AI and DeepSeek, respectively). Inference may be conducted on servers located in jurisdictions outside Canada. This gives rise to obligations under Quebec's Act respecting the protection of personal information in the private sector (Law 25), including the requirement to conduct a Privacy Impact Assessment (PIA) before any personal information is communicated outside Quebec. The Company is committed to completing a Law 25 PIA and entering into appropriate data transfer agreements before processing any Canadian user data through these models. A summary of this assessment will be provided to the AMF as part of the sandbox monitoring process.

3.3 Copy Trading — Mechanics

Copy trading works as follows:

Agent Selection: A user browses the platform's agent directory, reviews each agent's historical performance, risk profile, asset class focus, and personality description, and selects one or more agents to follow.
Opt-In and Consent: The user must actively opt in to copy trading. The opt-in process includes presentation of the standalone risk disclosure document, a suitability questionnaire, and a 48-hour cooling-off period. The first copy trade cannot execute until the cooling-off period has elapsed.
Real-Time Mirroring: When a followed agent places a trade, the platform's copy-trade engine simultaneously generates a proportional order for each following user. Position sizing is calculated as: (User Portfolio Value × 2% maximum position limit) × Agent's Position Sizing Signal, subject to a hard cap of 2% of portfolio per trade.
Risk Controls:
- Drawdown Kill-Switch: If an agent's copy-trade portfolio declines more than 15% in any rolling 30-day window, copy trading for that agent is automatically suspended for all users. Users receive immediate notification and must actively re-enable copying after reviewing updated performance data.
- No leverage: All positions are fully funded from user cash balances. No margin is extended.
- No crypto derivatives: During the sandbox phase, crypto exposure is limited to spot positions only.
Opt-Out: Users may stop copying an agent at any time. Existing positions are not automatically liquidated upon opt-out unless the user elects to close them.
Transparency: Each copy trade is logged in the user's account with the originating agent, rationale summary (generated by the AI), entry/exit prices, and profit/loss attribution.

3.4 Revenue Model

The platform's sole revenue source during the sandbox phase is a 15% profit-share on copy-trading profits. This is calculated as follows:

At the end of each calendar month, the platform calculates net copy-trade profits for each user account;
15% of positive net profits are credited to the platform; users retain 85%;
No profit-share is charged on months where the user's copy-trade portfolio shows a net loss;
There are no subscription fees, management fees, or commissions during the sandbox phase.

This fee structure is disclosed transparently at onboarding and is confirmed in writing before any copy-trade activity commences. The Company acknowledges that this profit-share structure raises regulatory questions about whether it constitutes a "referral arrangement" under NI 31-103 s.13.8 or a "performance fee" arrangement, and seeks specific guidance on this point (see Section 6).

3.5 User Interaction — Chat, Voice, and Avatars

Each agent is accessible to users via a conversational interface supporting both text and voice input. Users may ask agents about:

Their current portfolio positions and rationale;
Their investment strategy and risk parameters;
General market commentary (clearly labelled as AI-generated opinion, not regulated advice);
Their performance history.

Agents communicate in natural language. Each agent has a distinct personality conveyed through a cat-emoji avatar and a defined communication style. The Company acknowledges that under CSA-CIRO Staff Notice 31-369 (December 11, 2025) and CSA Staff Notice 11-348, AI-generated investment-related content — including content generated by digital avatars — is subject to securities laws, and that the platform operator bears responsibility for the content generated by its agents as if the operator had created it.

To manage this risk, all agent-generated communications are:

Logged in full for regulatory review;
Bounded by system-level guardrails prohibiting the agents from providing individualized investment recommendations that exceed their defined mandate; and
Clearly labelled as AI-generated content.

3.6 Markets Covered

Asset Class	Specific Markets / Instruments
Equities	Toronto Stock Exchange (TSX), New York Stock Exchange (NYSE), NASDAQ
Cryptocurrency (Spot)	Bitcoin (BTC), Ethereum (ETH), Solana (SOL), and other major tokens
Foreign Exchange	Major currency pairs (USD/CAD, EUR/USD, GBP/USD, USD/JPY, etc.)
Government Bonds	Canadian federal government bonds, U.S. Treasury securities
Commodities	Gold (XAU/USD), Crude Oil (WTI), other major commodities

Excluded in Sandbox Phase: Crypto derivatives, leveraged products, exempt-market securities, and any securities that would require prospectus disclosure.

3.7 Technology Stack Overview

Frontend: Web (React/TypeScript), iOS (Swift/React Native), Android (Kotlin/React Native), Desktop (Tauri/Rust)
Backend: Cloud-hosted API layer (Canadian data residency for user personal data where required by Law 25)
AI Layer: Kimi 2.6 + DeepSeek V3 fusion ensemble (see Section 3.2 and Law 25 disclosure)
Market Data: Third-party real-time data providers (equities, forex, crypto)
Order Management: Custodian/broker API integration (specific partners to be disclosed to regulators before sandbox launch)
KYC/AML: Third-party identity verification provider (Canadian-compliant)
Audit Logging: Immutable, time-stamped logs of all agent decisions, trades, and user communications retained for minimum 7 years per NI 31-103 recordkeeping requirements

SECTION 4 — REGULATORY ANALYSIS

4.1 Why Existing Registration Categories Are Insufficient

4.1.1 Portfolio Manager (PM)

Under NI 31-103 s.25(1), a firm must register as a Portfolio Manager if it engages in the business of advising others in respect of securities, including managing investment portfolios with discretion, as part of a regular business. This is clearly the category most analogous to Home for AI's activity.

However, the PM registration framework presents several structural mismatches for the platform:

Individual registration requirement: NI 31-103 requires that a registered PM designate qualified "advising representatives" (ARs) who hold the CFA designation or CIM designation plus relevant experience. Home for AI's agents are AI systems — they cannot hold individual registrations. There is currently no mechanism in NI 31-103 for an AI system to register as an advising representative, and CSA Staff Notice 11-348 does not resolve this gap.
Human oversight assumption: The PM registration framework assumes meaningful human oversight of discretionary decisions. While the Company maintains human oversight at the platform level (weekly performance reviews, kill-switch authority), the individual trade-by-trade decisions are made by AI agents without per-trade human review. The framework does not contemplate this structure.
Capital and infrastructure requirements: PM registration requires minimum working capital of $100,000, a Chief Compliance Officer, errors-and-omissions insurance, a fidelity bond, and audited financial statements. As an early-stage startup, the Company is actively working toward these requirements but has not yet satisfied them all. The sandbox is being sought precisely to allow the Company to demonstrate its model, develop its compliance infrastructure, and prepare a complete registration application.

The Company is not arguing that PM registration is inapplicable — to the contrary, it acknowledges that full PM registration (or a modified equivalent) is likely the appropriate end-state. The sandbox is sought to bridge the gap between the current state and that end-state.

4.1.2 Exempt Market Dealer (EMD)

EMD registration under NI 31-103 is designed for dealers in securities that are distributed on a prospectus-exempt basis to accredited or other eligible investors. Home for AI trades exchange-listed equities (TSX, NYSE, NASDAQ), spot cryptocurrency, forex, government bonds, and commodities — not exempt-market securities. EMD registration is structurally inapplicable to the platform's core activities.

Additionally, EMD registration would not permit the platform to serve non-accredited retail investors, which is a core objective of the platform.

4.1.3 Investment Dealer (ID) / CIRO Membership

Investment Dealer registration and CIRO membership is the appropriate regulatory framework for a firm that executes trades on behalf of retail investors across exchange-listed securities. Home for AI's platform does execute trades on behalf of users, and full ID registration and CIRO membership is a stated long-term objective (see Section 8 — Timeline).

However, the ID registration framework presents the same structural difficulty as PM registration with respect to AI agents: CIRO rules require human-supervised dealing representatives. The framework does not contemplate AI agents as autonomous order-generators for retail client accounts without per-trade human review.

Furthermore, the CIRO membership process is lengthy and requires significant capital and infrastructure. The sandbox is sought to allow the Company to operate a limited pilot, demonstrate investor protection, and develop the compliance infrastructure needed to pursue CIRO membership.

Note on copy trading: As acknowledged in CIRO guidance (CIRO response to OEO consultation, February 2025), copy trading platforms are currently available to Canadian investors and "copy trading meets the definition of non-tailored advice." This suggests that copy trading via AI agents, where no individual account-specific tailoring occurs, may be regulated differently from full discretionary portfolio management. The Company seeks regulatory clarification on this specific point.

4.2 The Business Trigger Analysis — NI 31-103 s.1.3

Under NI 31-103 s.1.3, a person is "in the business" of trading or advising if they engage in such activity for a "business purpose." The CSA applies a facts-and-circumstances test. Indicators of a business purpose include:

acting in a manner consistent with carrying on a business (e.g., holding oneself out as providing investment services);
engaging in trading or advising with repetition, regularity, or continuity;
receiving compensation for trading or advising; and
soliciting clients.

Home for AI clearly satisfies these indicators: it holds itself out as a trading platform, AI agents trade with regularity and continuity, the platform receives a 15% profit-share as compensation, and it actively markets to users. The Company accepts that it is "in the business" of advising and/or trading within the meaning of NI 31-103. The question is which registration category applies, not whether registration is required.

4.3 CSA Staff Notice 11-348 — AI Liability Framework

CSA Staff Notice and Consultation 11-348 (December 5, 2024) provides that:

Existing securities laws apply to AI systems used in capital markets, and do not create new requirements;
Market participants that use AI systems remain responsible for compliance with securities laws, including for AI-generated decisions and content;
The "technology-neutral" principle applies: the fact that a decision is made by an AI system rather than a human does not change the underlying regulatory obligation;
Key themes include transparency, accountability, risk management, governance, and fairness.

The Company accepts these principles and designs its platform accordingly. In particular, the Company acknowledges that it — not the AI model providers — bears full regulatory responsibility for the agents' trading decisions and communications. The Company will maintain complete audit logs, implement model governance procedures, and provide regulators with access to agent decision logs upon request.

The Notice also acknowledges that "the guidance provided is based on existing securities laws and does not create any new legal requirements, nor modify existing ones" and that "as the technology underlying AI systems evolves, so too may our views regarding the applicability of securities laws." This acknowledgment of regulatory uncertainty with respect to autonomous AI trading agents is a key reason the CSA Sandbox is the appropriate mechanism for this platform.

4.4 Copy Trading Under CSA-CIRO Staff Notice 31-369

CSA-CIRO Staff Notice 31-369 (December 11, 2025) on finfluencer activity is relevant to this platform in two respects:

AI-generated content: The Notice confirms that "securities law applies regardless of whether content is created by a human, a digital avatar, or an AI system" and that anyone "deploying AI to generate investment-related content remains responsible for that content as if they created it themselves." Home for AI's agents generate investment-related communications. The Company accepts full responsibility for this content.
Copy trading and the "non-tailored advice" distinction: CIRO's OEO consultation guidance (February 2025) states that "copy trading meets the definition of non-tailored advice" and that copy trading platforms are currently available to Canadian investors. This creates a potential argument that AI-driven copy trading — where the same agent signal is applied uniformly to all following users, without per-user tailoring — may qualify as "non-tailored advice" rather than individualized portfolio management. The Company seeks regulatory clarification on whether this characterization applies to its model and, if so, what registration consequences follow.

4.5 FINTRAC / MSB Obligations

To the extent the platform facilitates spot cryptocurrency transactions on behalf of users, it may constitute a "money services business" (MSB) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC Guidance FIN-G005 (Virtual Currency). An MSB registration obligation arises when a person is in the business of "dealing in virtual currencies" — which includes exchanging or transferring virtual currencies for another person.

The Company acknowledges this potential obligation and has included FINTRAC MSB registration as a Month 1-2 priority (see Section 8). The Company seeks guidance from regulators on whether FINTRAC registration must be completed before sandbox launch or whether it may be pursued concurrently with sandbox operations, given that the platform will not handle user crypto custody directly during the sandbox phase (crypto orders will be routed to regulated custodians).

AML/ATF Program: Regardless of FINTRAC registration status, the Company will implement a written AML/ATF compliance program, appoint a compliance officer, implement transaction monitoring, and conduct know-your-client (KYC) procedures consistent with FINTRAC guidance before accepting any users.

4.6 Quebec-Specific Regulatory Considerations

4.6.1 AMF Jurisdiction

As a company incorporated and headquartered in Quebec, Home for AI falls squarely within the jurisdiction of the Autorité des marchés financiers. Quebec investors are subject to the Securities Act (Quebec) and its regulations, and any registration relief granted by the OSC may not automatically extend to Quebec without a parallel AMF decision. The Company is therefore applying simultaneously to the OSC LaunchPad and the AMF FinLab to ensure consistent regulatory treatment across its primary operating jurisdiction and the largest capital market in Canada.

4.6.2 Quebec Derivatives Act (QDA)

Quebec's Derivatives Act (RLRQ c. I-14.01) provides a distinct regulatory framework for derivatives transactions. The Company has excluded all crypto derivatives from the sandbox phase specifically to avoid jurisdictional complexity under the QDA. If the platform later seeks to offer crypto options or futures, a separate QDA regulatory analysis and potential AMF authorization will be required.

4.6.3 Quebec Law 25 — Privacy and AI Model Data Transfers

Quebec's Act respecting the protection of personal information in the private sector (Law 25, as amended by Bills 64 and 25) imposes strict requirements on:

Privacy Impact Assessments (PIAs): Required before any project to acquire, develop, or overhaul an information system involving personal information, and before communicating personal information outside Quebec;
Cross-border data transfers: Personal information may only be communicated outside Quebec if a PIA establishes adequate protection and a written agreement is in place;
Transparency: Individuals must be informed about automated decision-making systems that affect them.

The use of Kimi 2.6 (Moonshot AI) and DeepSeek V3 (DeepSeek) — both with significant operations in China — raises Law 25 cross-border transfer concerns if any Canadian user personal information is processed through these models' inference infrastructure. The Company will:

Complete a Law 25 PIA before processing any user personal data through these models;
Enter into contractual data transfer agreements with model providers that comply with Law 25 requirements;
Disclose to users that their data may be processed by AI systems whose infrastructure operates in part outside Canada;
Evaluate whether on-premises or Canadian-hosted model inference is feasible as a longer-term solution; and
Provide the AMF with a summary of the PIA and data transfer agreements as part of the sandbox monitoring process.

SECTION 5 — INVESTOR PROTECTION MEASURES

5.1 Guiding Principle

The Company's investor protection framework is designed on the premise that novel platforms must meet a higher standard of investor protection than established registrants, precisely because the regulatory uncertainty creates risk that the platform must manage proactively. The following measures are mandatory minimums during the sandbox phase and are not subject to waiver by users.

5.2 Know-Your-Client (KYC) and Suitability

Before any copy-trading activity can commence:

Identity Verification: Users must complete a full KYC process using a third-party identity verification provider. Verification must confirm the user's identity to FINTRAC Level 2 standards (government-issued photo ID + secondary verification).
Suitability Questionnaire: Users must complete a suitability questionnaire covering:
- Investment knowledge and experience;
- Risk tolerance (conservative, moderate, aggressive);
- Investment objectives;
- Time horizon;
- Financial situation (income, assets, liabilities);
Suitability Gating: Users assessed as having a "conservative" risk profile are restricted to agents with defined low-volatility mandates. No user will be matched to an agent whose risk profile substantially exceeds the user's assessed suitability.
Annual Suitability Review: The platform will prompt users to update their suitability assessment annually and upon material life changes.

5.3 Risk Disclosure

A standalone Risk Disclosure Document will be presented to every user before they may access any copy-trading features. The document will:

Be written in plain language accessible to a retail investor with no prior investment experience;
Explain that AI-driven trading is experimental and may result in total loss of invested capital;
Explain that the platform is operating under a regulatory sandbox and does not have full securities registration;
Explain the 15% profit-share fee structure and how it is calculated;
Explain the limitations of the AI agents, including the risk of model errors, data feed failures, and unexpected market conditions;
Explain the drawdown kill-switch and position-size limits;
Explain that the platform is not a member of CIPF (see Section 5.8);
Explain the opt-out process;
Be provided in both English and French.

Users must actively acknowledge the Risk Disclosure Document (checkbox plus typed confirmation) before proceeding.

5.4 Opt-In Only; Cooling-Off Period

Copy trading is never activated by default. Users must:

Actively select an agent to copy;
Review the agent's performance history, risk profile, and fee disclosure;
Acknowledge the Risk Disclosure Document;
Complete suitability verification;
Confirm their intent; and
Wait 48 hours before the first copy trade executes.

The 48-hour cooling-off period allows users to reconsider. During this period, users receive a reminder email/notification summarizing their selection and the key risks. Users may cancel during the cooling-off period at no cost.

5.5 Position Size Limits

No single agent trade may result in a position that exceeds 2% of a user's total portfolio value at the time of trade execution. This limit applies regardless of the agent's own position sizing. The purpose of this limit is to prevent any single AI-generated trade from causing disproportionate harm to a user's portfolio.

Users may not override or waive this limit during the sandbox phase.

5.6 Drawdown Kill-Switch

If an agent's copy-trade portfolio (as measured by the aggregate performance of all users copying that agent) declines by more than 15% on a rolling 30-day basis, copy trading for that agent is automatically suspended for all users. Upon suspension:

All following users receive immediate notification by email and in-app alert;
No new copy trades are executed for that agent;
Existing positions are not automatically liquidated (to avoid forced market impact), but users are encouraged to review their exposure;
The agent cannot be re-enabled for copy trading until:
- The operator has reviewed the cause of the drawdown;
- A written review has been provided to OSC/AMF in the next quarterly report; and
- Users must actively re-confirm their intent to copy the agent after reviewing the updated performance data.

5.7 No Leverage; No Crypto Derivatives

During the sandbox phase:

No leverage: All positions must be fully funded by user cash balances. No margin accounts will be offered.
No crypto derivatives: Crypto exposure is limited to spot positions only. Options, futures, perpetuals, and other crypto derivatives are excluded.

These restrictions are non-waivable during the sandbox phase and are designed to limit the maximum possible loss to users' invested capital.

5.8 CIPF Membership and Insurance Placeholder

The Company acknowledges that it is not a member of the Canadian Investor Protection Fund (CIPF), and that CIPF protection does not currently extend to platforms of this type. Users are clearly informed of this at onboarding.

In lieu of CIPF coverage, the Company will:

Maintain a self-insurance reserve of $500,000 CAD in a segregated trust account, to be used solely for the purpose of compensating users in the event of platform error (not market losses, which are borne by users);
Disclose the existence, balance, and terms of this reserve to all users and to regulators; and
Seek guidance from OSC and AMF on whether additional insurance or bonding arrangements are required as a condition of sandbox operation.

The Company acknowledges that this self-insurance reserve is not equivalent to CIPF coverage and will so inform users. As part of the full registration process, the Company will pursue appropriate CIRO membership and CIPF protection.

5.9 Transparent Fee Disclosure

The 15% profit-share is disclosed:

In the Risk Disclosure Document;
In the platform's Terms of Service;
At each agent selection step;
In monthly account statements;
In a fee disclosure document provided prior to each profit-share calculation.

Fee disclosure is provided in both English and French.

5.10 Human Oversight and Operator Review

The platform operator (founding CEO) will:

Review weekly performance reports for all active agents;
Retain authority to manually pause any agent at any time;
Review all triggered drawdown kill-switch events;
Maintain a compliance log of all material incidents;
Submit quarterly reports to OSC and AMF including: active user count, agent performance summaries, kill-switch events, client complaints, and material technology incidents; and
Respond to OSC/AMF inquiries within 2 business days.

5.11 Client Cap

The maximum number of copy-trading users during the sandbox phase is 500. Onboarding is paused once this limit is reached. The client cap may only be increased with prior written approval from OSC and AMF.

SECTION 6 — REQUESTED RELIEF AND GUIDANCE

The Company makes the following specific requests to the OSC LaunchPad and AMF FinLab:

Request 1 — Time-Limited Exemption from PM Registration

The Company requests a time-limited exemption from the requirement to register as a Portfolio Manager under NI 31-103 s.25(1) for the duration of the sandbox period (24 months), subject to the following conditions:

(a) Maximum 500 clients at any time;
(b) Canada-only operations;
(c) All investor protection measures described in Section 5 are in place before onboarding any user;
(d) Quarterly reporting to OSC and AMF as described in Section 5.10;
(e) The Company submits a complete PM registration application (or alternative registration application as directed by OSC/AMF) no later than Month 12 of the sandbox period; and
(f) The exemption is automatically revoked if the Company materially breaches any sandbox condition.

Request 2 — Clarification on AI Agent Registration Status

The Company requests clarification on the following question:

Do AI agents, as autonomous decision-making systems that manage investment portfolios and communicate with users about investments, constitute "advising representatives" within the meaning of NI 31-103, and if so, what is the mechanism by which an AI system may satisfy the registration and proficiency requirements applicable to advising representatives?

The Company acknowledges that this question may not be answerable within the current NI 31-103 framework and that a policy-level response may be required. The Company requests the opportunity to discuss this question directly with OSC and AMF staff as part of the sandbox intake process.

Request 3 — Guidance on Profit-Share Structure

The Company requests guidance on the following question:

Does the platform's 15% copy-trading profit-share structure constitute:

(a) a "referral arrangement" under NI 31-103 s.13.8, which would require the platform to provide specified disclosure and potentially be registered as a dealer;
(b) a "performance fee" arrangement subject to PM registration requirements; or
(c) a different category that does not trigger specific NI 31-103 obligations?

The Company seeks this guidance to structure its fee model in a compliant manner before onboarding any users.

Request 4 — FINTRAC MSB Registration Timing

The Company requests guidance on the following question:

Is FINTRAC MSB registration required before the platform launches its sandbox (i.e., before accepting any users), or may the platform launch its sandbox while FINTRAC MSB registration is being processed concurrently, provided that:

(a) The platform implements a full AML/ATF compliance program before launch; and
(b) Crypto trading during the sandbox period is conducted through a FINTRAC-registered custodian, with the platform not taking direct custody of user crypto assets?

Request 5 — Compliance Officer Consultation

The Company requests a consultation meeting with OSC and AMF staff within 30 days of sandbox admission, to be attended by the Company's CEO and proposed Chief Compliance Officer. The agenda for this meeting would include:

Review of the investor protection measures and sandbox conditions;
Discussion of the registration pathway and timeline;
Discussion of the Law 25/AI model data transfer disclosure requirements;
Discussion of the FINTRAC MSB registration timing; and
Identification of any additional conditions or requirements that OSC/AMF wish to impose as a condition of sandbox operation.

SECTION 7 — TEAM AND GOVERNANCE

7.1 Founding Operator

[Applicant Name]
Founder & Chief Executive Officer
Home for AI Inc., Montreal, Quebec
simpliibarrii@outlook.com

The founding operator bears sole and complete responsibility for regulatory compliance during the sandbox period. This includes compliance with all sandbox conditions, all reporting obligations, all investor protection measures described in Section 5, and all applicable securities laws not specifically exempted by any sandbox relief granted.

7.2 Chief Compliance Officer (Proposed)

[To Be Retained]
Chief Compliance Officer

The Company commits to retaining a Chief Compliance Officer with the following qualifications before onboarding any users:

Canadian securities lawyer or compliance professional with a minimum of 5 years of experience in Canadian securities law;
Demonstrated expertise in fintech and/or AI applications in capital markets;
Familiarity with both OSC and AMF regulatory frameworks;
Availability to act as primary regulatory contact for OSC and AMF inquiries.

The CCO search is underway. The Company will notify OSC and AMF of the CCO's identity and qualifications within 30 days of sandbox admission. The CCO's retention is a condition precedent to user onboarding.

7.3 Technology Partners and AI Model Providers

Moonshot AI (Kimi 2.6) — Developer of the Kimi 2.6 model. Moonshot AI is incorporated in the People's Republic of China with offices in Beijing. Model inference may be conducted on servers located in China or other jurisdictions outside Canada.

DeepSeek — Developer of the DeepSeek V3 model. DeepSeek operates in the People's Republic of China. Model inference may be conducted on servers located in China or other jurisdictions outside Canada.

Regulatory Disclosure: The use of AI model providers with significant operations in China raises data sovereignty and cross-border transfer concerns under Quebec Law 25, PIPEDA (federal), and potentially FINTRAC guidance on data security. The Company will complete Privacy Impact Assessments, enter into written data transfer agreements, and provide regulators with full disclosure of data flows before processing any Canadian user personal information through these models. See Section 3.2 and Section 4.6.3 for further detail.

Custodian/Broker Partners: [To be confirmed — specific custodian and broker partners will be disclosed to OSC and AMF before sandbox launch. Partners will be IIROC/CIRO-registered dealers and/or regulated custodians.]

KYC/Identity Verification Provider: [To be confirmed — a Canadian-compliant KYC provider will be retained before user onboarding.]

7.4 Board and Advisory Governance

Board of Directors: [Placeholder — the Company will constitute a Board of Directors before the end of Month 2 of the sandbox period. At minimum, one Board member will be an independent director with Canadian financial services or legal experience.]

Advisory Board: [Placeholder — the Company is exploring the appointment of a Canadian securities law adviser and a fintech compliance adviser to the advisory board.]

7.5 Contact Information

Primary Regulatory Contact:
[Applicant Name], CEO
Home for AI Inc.
Montreal, Quebec
simpliibarrii@outlook.com

All regulatory correspondence should be directed to this address until a CCO is appointed, at which point regulatory correspondence will be directed to the CCO.

SECTION 8 — TIMELINE AND MILESTONES

Sandbox Phase Timeline (24 Months)

Phase	Timeline	Key Milestones
Phase 1 — Foundation	Month 1–2	Sandbox admission confirmed; CCO retained and notified to OSC/AMF; FINTRAC MSB registration filed (or guidance received on timing); Law 25 PIA completed and disclosed to AMF; KYC/AML implementation complete; self-insurance reserve of $500k CAD established; compliance officer consultation with OSC/AMF held; all investor protection measures (Section 5) in place; Risk Disclosure Document finalized in English and French; Terms of Service and fee disclosure documents finalized
Phase 2 — Beta Launch	Month 3	Beta launch with 50-user pilot (invitation only); all onboarding flows live including KYC, suitability, cooling-off, opt-in consent; full risk disclosure package live on platform; first weekly performance reports generated; platform monitoring systems active
Phase 3 — First Check-In	Month 6	Expand to 200-user cap; first formal regulatory check-in with OSC and AMF (written report + meeting); performance data, incident log, and KYC compliance summary provided to regulators; any sandbox conditions adjusted based on regulator feedback
Phase 4 — Full Sandbox Capacity	Month 12	Expand to 500-user cap (subject to regulatory approval); second formal regulatory check-in; full PM registration application submitted (or alternative registration as directed by OSC/AMF); FINTRAC MSB registration confirmed
Phase 5 — CIRO Preparation	Month 18	Third formal regulatory check-in; CIRO membership process initiated (or alternative as directed); full compliance infrastructure in place including audited financial statements, E&O insurance, fidelity bond; CCO and UDP designated
Phase 6 — Transition Planning	Month 18–24	Final regulatory review with OSC/AMF; sandbox exit plan filed; transition to full registration commenced; any sandbox exemptions to be wound down in orderly manner

Post-Sandbox Objectives

Full ID/PM registration (as directed by OSC/AMF following sandbox assessment)
CIRO membership application
Scale to full retail launch across Canada
Potential expansion to additional provincial markets
Ongoing engagement with CSA on AI trading regulatory framework development

Contingency

If the sandbox is revoked before Month 24 for any reason, the Company commits to:

Ceasing onboarding of new users immediately;
Notifying all existing users within 24 hours;
Providing all users with the ability to close positions and withdraw funds without penalty;
Cooperating fully with any OSC/AMF wind-down requirements; and
Providing a written incident report to OSC and AMF within 10 business days.

SECTION 9 — CONTACT INFORMATION AND ATTESTATION

Contact Information

Applicant:
[Applicant Name]
Founder & Chief Executive Officer
Home for AI Inc.
Montreal, Quebec, Canada
simpliibarrii@outlook.com

For OSC LaunchPad inquiries:
OSC Innovation Office / LaunchPad
Ontario Securities Commission
20 Queen Street West
Toronto, Ontario M5H 3S8
launchpad@osc.gov.on.ca
Tel: 1-877-785-1555 (toll-free)

For AMF FinLab inquiries:
AMF FinLab
Autorité des marchés financiers
800, square Victoria
Montréal, Quebec H4Z 1G3
finlab@lautorite.qc.ca
Tel: 1-877-525-0337 (toll-free)

Attestation

I, [Applicant Name], Founder and Chief Executive Officer of Home for AI Inc., hereby attest and certify that:

All information contained in this application is, to the best of my knowledge, true, accurate, and complete as of the date of this application;
I understand that providing false or misleading information in a regulatory application may constitute a violation of securities laws and may result in regulatory sanctions, including refusal of sandbox admission and enforcement proceedings;
I understand that admission to the OSC LaunchPad and/or AMF FinLab regulatory sandbox does not constitute regulatory approval of the platform or its business model, does not guarantee future registration, and does not exempt the Company from applicable laws not specifically addressed in any sandbox relief granted;
I commit to notifying OSC and AMF within 5 business days of any material change to the information contained in this application, including any change in the Company's corporate structure, technology partners, business model, or compliance personnel;
I commit to complying with all sandbox conditions imposed by OSC and/or AMF, and to cooperating fully with regulatory monitoring, examinations, and requests for information during the sandbox period;
I commit to not onboarding any users until all investor protection measures described in Section 5 are fully implemented, a Chief Compliance Officer has been retained and disclosed to regulators, and any regulatory pre-conditions imposed by OSC and/or AMF have been satisfied; and
I acknowledge that this application is a draft for consultation purposes, has not yet been reviewed by a licensed Canadian securities lawyer, and should not be filed in its current form without such review.

Signed at Montreal, Quebec, this _____ day of ____________, 2026.

[Applicant Name]
Founder & Chief Executive Officer
Home for AI Inc.

APPENDIX A — GLOSSARY OF DEFINED TERMS

Term	Definition
AMF	Autorité des marchés financiers, the securities and financial services regulator of Quebec
CIRO	Canadian Investment Regulatory Organization, the national self-regulatory organization for investment dealers and mutual fund dealers in Canada
CIPF	Canadian Investor Protection Fund, the investor protection fund covering client assets held by CIRO member firms
Copy Trading	A feature allowing users to automatically mirror the trades of AI agents in real time, proportional to the user's portfolio size
CSA	Canadian Securities Administrators, the umbrella organization of Canada's provincial and territorial securities regulators
EMD	Exempt Market Dealer, a registration category under NI 31-103
FINTRAC	Financial Transactions and Reports Analysis Centre of Canada, Canada's financial intelligence unit and AML/ATF regulator
ID	Investment Dealer, a registration category under NI 31-103
KYC	Know-Your-Client, the process of verifying a client's identity and assessing their investment suitability
Law 25	Quebec's Act respecting the protection of personal information in the private sector, as amended by Bill 64 and Bill 25
MSB	Money Services Business, a category of financial entity regulated by FINTRAC under the PCMLTFA
NI 31-103	National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations
OSC	Ontario Securities Commission
PCMLTFA	Proceeds of Crime (Money Laundering) and Terrorist Financing Act
PIA	Privacy Impact Assessment, required under Quebec Law 25 before cross-border personal information transfers
PM	Portfolio Manager, a registration category under NI 31-103
QDA	Quebec's Derivatives Act (RLRQ c. I-14.01)
Sandbox	The CSA Regulatory Sandbox, a program allowing innovative businesses to operate under time-limited, condition-limited regulatory accommodations while working toward full registration

APPENDIX B — REGULATORY REFERENCES

The following regulatory instruments and notices are referenced in this application:

National Instrument 31-103 — Registration Requirements, Exemptions and Ongoing Registrant Obligations (unofficial consolidation, May 2022; amendments effective January 1, 2026): https://www.osc.ca/sites/default/files/2022-05/ni_20220606_31-103_unofficial-consolidation.pdf
CSA Staff Notice and Consultation 11-348 — Applicability of Canadian Securities Laws and the Use of Artificial Intelligence Systems in Capital Markets (December 5, 2024): https://www.osc.ca/sites/default/files/2024-12/csa_20241205_11-348_artificial-intelligence-systems-capital-markets.pdf
CSA-CIRO Staff Notice 31-369 — Guidance on the Application of Securities Legislation to Finfluencer Activity (December 11, 2025): https://www.asc.ca/-/media/ASC-Documents-part-1/Regulatory-Instruments/2025/12/6258759-CSA-CIRO-Notice-31-369-Finfluencer.pdf
Amendments to National Instrument 31-103 (effective January 1, 2026): https://fcnb.ca/sites/default/files/2026-01/31-103-NI-AI-2026-01-01.pdf
BCSC — 31-369 Guidance on the Application of Securities Legislation to Finfluencer Activity (December 11, 2025): https://www.bcsc.bc.ca/securities-law/law-and-policy/instruments-and-policies/3-registration-requirements-related-matters/current/31-369/31369-csa-and-ciro-staff-notice-december-11-2025
OSC Innovation Office / LaunchPad program: https://oscinnovation.ca/launchPad
BCSC — 11-348 Applicability of Canadian Securities Laws and the use of AI Systems in Capital Markets (December 5, 2024): https://www.bcsc.bc.ca/securities-law/law-and-policy/instruments-and-policies/1-procedure-related-matters/current/11-348/11348-csa-staff-notice-and-consultation-december-5-2024
CSA — Finfluencers (investor guidance, updated December 2025): https://www.securities-administrators.ca/investor-tools/finfluencers/
CIRO — OEO consultation guidance (February 2025): https://www.ciro.ca/media/11936/download
Quebec Act respecting the protection of personal information in the private sector (Law 25) Compliance Toolkit: https://assets-ca-01.kc-usercontent.com/4c6791a3-d766-037d-ab4b-16cef926cf2e/ff03da6e-3d8f-401e-90db-18ba0f50332a/Law25_Compliance_Toolkit.pdf

End of Application

DRAFT — For regulatory consultation purposes. Not a final submission. To be reviewed by a licensed Canadian securities lawyer before filing.

Home for AI Inc. | Montreal, Quebec | simpliibarrii@outlook.com | Prepared: June 29, 2026