In connection with refusing to rule because the proposed transactions related to a wide range of funds for which documentation had not been provided, CCRA went on to provide general comments. When units of a class or series of a mutual fund trust are changed (i.e, reclassified or redesignated) to another class or series of the same mutual fund trust, there is no disposition if the trust agreement provides that more than one class or series of units may be issued by the fund and it makes provision for changes between classes or series of units of that fund.
Inherent in these rulings was our understanding that the attributes of each class or series of units of a particular fund were substantially the same (even though each class or series may have different investment requirements), the unit holders would not be entitled to proceeds of disposition for the units, and the redesignated or reclassified units would not be cancelled or redeemed. Also, the fact that a unit holder may have to pay an initial sales charge or a deferred sales charge in respect of the redesignated or reclassified units did not alter our view that there was not a disposition of units.