CIRO’s proposed dual registration amendments
This submission supports a more flexible and efficient regulatory framework that simplifies how investment dealers operate and serve clients.
Submission – CIRO – Proposed Dual Registration Amendments – Proposed CIRO Rules
Recipients
Canadian Investment Regulatory Organization (CIRO)
Industry segments this resource supports
- Wealth management
Summary
We provided comments on CIRO’s proposed dual-registration amendments under the rule-consolidation project, supporting the move to eliminate dual registration requirements and create a unified regulatory framework. The submission highlights the benefits of reducing duplication, improving flexibility in firm structures and enhancing advisor mobility while recommending clearer guidance to ensure consistent and principles-based implementation.
Why this matters: This submission supports a more flexible and efficient regulatory framework that simplifies how investment dealers operate and serve clients.
Key takeaways
- SIMA supports eliminating the dual registration construct to simplify regulatory requirements and reduce duplication.
- The proposed amendments allow investment dealers to operate mutual fund divisions without separate registration, increasing operational flexibility.
- Removing the 270-day proficiency upgrade requirement and codifying exemptive relief enhances transparency and efficiency.
- The changes are expected to lower regulatory burden and operating costs while improving client outcomes through service continuity and fewer account transfers.
- SIMA recommends that CIRO clearly articulate that the framework is principles-based and not prescriptive, and that they provide supporting supervisory guidance.
