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Insights

Everything you need to know about the Canadian Investment Regulatory Organization (CIRO): a dynamic resource

Welcome to BLG and AUM Law’s dynamic resource on the Canadian Investment Regulatory Organization (CIRO). We invite you to bookmark and revisit this page which will be updated to reflect developments of importance to CIRO registered firms. Resulting from the amalgamation of the Investment Industry Regulatory Organization of Canada (IIROC) and the Mutual Fund Dealers Association of Canada (MFDA), CIRO has been operating since January 1, 2023 and has led to – and will continue to generate – significant changes in the registration and oversight of investment and mutual fund dealers across Canada, as well as new opportunities. This resource is designed to help you find, understand and act on CIRO-related topics, such as new developments, rules, registration requirements, enforcement and examinations and more.

Recent developments

  • On July 16, 2024 - CIRO released its 2023 – 2024 Enforcement Report. The report highlights the continuing integration and evolution of CIRO mutual fund dealer and investment dealer enforcement functions, selected cases, and statistics on activities during the year. It is an interesting read for all stakeholders.

  • On June 27, 2024 – CIRO published an Implementation Bulletin announcing the approval of amendments to improve the clarity of the registration and proficiency requirements in the Investment Dealer and Partially Consolidate Rules (IDPC Rules). The amendments will be effective September 28, 2024.

  • On April 25, 2024 – CIRO published for comment a Proposed Integrated Fee Model. The proposed fee model is comprised of three components: Annual Dealer Member Fee, Application and Business Change Fees, and a Qualified Market Maker Discount. Annual Dealer Member Fees are proposed to be calculated based on the greater of a Minimum Fee, and an amount based on the Dealer Member's total revenue, plus a component based on the number of Approved persons at the Dealer Member. There will also be a minimum threshold amount for Mutual Fund Dealers only. There is also allowance for Québec based Mutual Fund Dealers during the transition period to CIRO regulation. Stakeholders have until June 24, 2024 to comment. Read BLG Beyond AUM Law’s article here.

  • On April 18, 2024 – CIRO released for comment Phase 3 of the proposed changes to harmonize the two rule sets currently applicable to investment dealers and to mutual fund dealers into one set of rules. The Phase 3 changes concern rules to be retained that are common to the IDPC and MFD Rules and have been assessed as not having a material impact on stakeholders. The Phase 3 Proposed DC Rules involve the adoption of rules relating to membership and member business activity approval matters, clearing and settlement of trades and trade delivery standards, and examination, and, investigation and enforcement rules. The comment period is open until July 17, 2024.
  • On April 11, 2024 – CIRO released it inaugural Three-Year Strategic Plan. The document is wide ranging and is an important read for all CIRO member dealers. CIRO set out their newly adopted Vision, Mission, and Values. They also identify Transformational Initiatives, including a proposal to “standardize KYC”, and provide a detailed list of Strategic Objectives for all divisions of CIRO. It is a bold plan that CIRO members should make themselves familiar with.
  • On March 13, 2024 – CIRO released CIRO Compliance Priorities Report for 2024: Helping Firms with Compliance. The document is wide ranging and is an important read for all CIRO member dealers. CIRO continue to align processes and procedures from the legacy organizations. Also, a focus on implementation and compliance with the Client Focussed Reforms continues.

Key Contacts

BLG Beyond AUM Law - Bill Donegan

 

AUM Law Professional Corporation 

 

Regulatory Compliance Counsel and Consultants to Securities Registrants – AUM Law was founded in 2009 with a vision to serve the regulatory compliance needs of securities registrants. AUM Law has been part of Borden Ladner Gervais LLP (BLG) since May 2021 and is integrated with BLG’s suite of alternative legal services known as BLG Beyond. AUM Law offers practical, cost-effective legal and consulting advice on securities regulatory compliance matters.

 

Practical Advice. Efficient Service. Fixed-Fee Plans. Singular Focus.