● File 2025-18Decision: Reserved / Pending

75% vs Under 35%: The Number at the Centre of the Purpose Investments ESG Case

The OSC alleges that Purpose publicly represented in 2019 that funds accounting for approximately 75% of its assets under management were already operating within the firm's ESG framework. The regulator contends the actual proportion supported by the relevant funds was substantially lower. Purpose disputes the allegations.

Direct Answer

Did Purpose Investments claim 75% of its assets were ESG-integrated?

The OSC alleges that Purpose represented in 2019 that funds representing roughly 75% of assets under management were operating within its ESG framework, while the regulator's analysis places the supported figure in the approximate range of 29%–35%. Purpose disputes the OSC's interpretation and methodology. The Tribunal has not ruled.

Important

The allegations described on this website have not yet been determined by the Capital Markets Tribunal. Purpose Investments and Som Seif deny wrongdoing and vigorously contested the OSC's case. Until the Tribunal issues its decision, all disputed allegations must be described as allegations.

The Number Dispute

Purpose Position (as alleged by OSC)
~75%

Publicly communicated figure — the proportion of AUM the OSC says Purpose represented as operating within its ESG framework in 2019.

vs
OSC Position
~29–35%

OSC analysis — the figure the regulator says was actually supported by the relevant funds.

These figures represent opposing positions in an unresolved regulatory proceeding. The lower figure is the OSC's analysis, not an independently established fact.

What the OSC Alleges

The OSC alleges that in 2019, Purpose stated that funds representing approximately 75% of its assets under management were already operating within the firm's ESG framework. The regulator contends this representation overstated the proportion of AUM for which ESG factors were meaningfully incorporated into investment decisions.

According to reporting on the OSC's evidence, the regulator's analysis of the relevant funds placed the supported figure in the approximate range of 29%–35%. The OSC says the gap between the communicated figure and the supported figure is central to its allegation that the communications were false or misleading.

Purpose's Position

Purpose disputes the OSC's interpretation of the 75% representation and the regulator's methodology for arriving at the under-35% figure. Purpose has argued that its ESG efforts represented corporate philosophy and investment thinking rather than the rigid fund classification the regulator seeks to impose, and that the communications must be understood in context.

OSC Position

The 75% representation overstated ESG integration; the supported figure was ~29–35%.

Purpose Position

The OSC's interpretation and methodology are wrong; the communications were not misleading in context.

Why This Number Matters

The 75% vs under-35% dispute is one of the most quantifiable elements of the OSC's case. It frames the central question: did Purpose's public communications about ESG integration accurately describe the firm's actual practice, or did they overstate it? The Tribunal's eventual decision will assess the evidence on both sides.

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