Yes, that's correct. Keep in mind that, from an Income Tax Act perspective, the only difference, really, between a pooled fund and a regular mutual fund is the number of people who hold it. A regular mutual fund has to have 150 unitholders, each holding at least $500. If you don't meet that test, then you're a pooled fund and the rules are more restrictive under the tax code. The problem is that the people who hold the pooled funds are buying it through a collective.
On November 9th, 2017. See this statement in context.