SIMA responds to final phase of CIRO’s rule-consolidation project
Association supports initiative but asks for longer transition periods and clear guidance
June 12, 2026 (Toronto) — The Securities and Investment Management Association (SIMA) today submitted comments on the final phase of CIRO’s rule-consolidation project. The initiative aims to harmonize the separate rules that currently govern CIRO’s mutual fund dealers and investment dealers by aligning similar activities and by introducing a more uniform, principles‑based, scalable framework that reflects the varied sizes and business models of CIRO‑regulated dealers.
In its submission, SIMA reaffirms its strong support for the project and thanks CIRO for its leadership and sustained effort since the initiative was launched in 2023. At the same time, SIMA highlights the significant operational impact the proposed consolidated rules will have on dealers—particularly mutual fund dealers—and urges CIRO to collaborate with dealers to develop a thoughtful, informed implementation plan.
“We support CIRO’s modernization efforts and look forward to working together to ensure the implementation is practical and achievable,” said Andy Mitchell, SIMA’s President and CEO. “CIRO’s delivery of guidance to its dealers before implementation periods begin will be critical to the dealers’ ability to meet CIRO’s implementation deadlines.”
To support an orderly transition, SIMA emphasizes the need for timely, practical regulatory guidance, careful calibration of key requirements, and clear implementation timelines that reflect the substantial work required to operationalize the new framework. SIMA also warns that, as drafted, the proposed rules could create cumulative operational pressures and interpretive uncertainty for smaller dealers. To mitigate these risks, SIMA is calling for more proportionate requirements, clearer definitions, and finalized guidance that aligns supervisory expectations with mutual fund dealer business models.
SIMA recommends a minimum implementation period of 24 months for the majority of the rules, and a 36‑month transition period for mutual fund dealers to meet the new requirement to identify and retain CIRO-approved CFOs and panel auditors.
SIMA says the consolidated rules can deliver their intended benefits, provided CIRO continues to refine key elements related to implementation, proportionality, and supporting guidance. A coordinated, “one‑and‑done” implementation approach, paired with finalized guidance and reasonable timelines, would maximize the effectiveness of the new regulatory framework while minimizing unnecessary disruption for dealers.
About SIMA
The Securities and Investment Management Association empowers Canada’s investment industry. It is the leading voice for the securities and investment management industry, which oversees approximately $4 trillion in assets for over 20 million investors and Canadian capital markets participants. SIMA members—including investment fund managers, investment and mutual fund dealers, capital markets participants, and professional service providers—are committed to creating a resilient, innovative investment sector that fuels long-term economic growth and creates opportunities for all Canadians.
For more information
Christine Harminc
Director, Communications and Public Affairs
charminc@sima-amvi.ca
416-309-2313
