CIRO proposal to modernize and clarify regulatory framework for OEO account services
The proposed guidance will shape how DIY investors receive tools and information without crossing into prohibited recommendations.
Submission – CIRO – Proposed guidance on OEO account services and activities
Recipients
Canadian Investment Regulatory Organization (CIRO)
Member Regulation Policy
Industry segments this resource supports
- Wealth management
Summary
We support CIRO’s proposed guidance to modernize and clarify the regulatory framework for order-execution-only (OEO) account services. We endorse CIRO’s principles based approach, narrower definition of prohibited recommendations, and expanded allowance for decision making supports, while also identifying areas needing refinement, such as terminology clarity, business-model neutrality, conflict of interest expectations, and flexibility for innovation.
Why this matters: The proposed guidance will shape how DIY investors receive tools and information without crossing into prohibited recommendations.
Key takeaways
- SIMA supports CIRO’s initiative to modernize OEO regulation and provide clearer expectations for OEO dealers.
- SIMA emphasizes the need for precise definitions, especially around “recommendation,” “specific investment decision,” and “very limited range of products.”
- SIMA urges CIRO to ensure business model neutrality so that proprietary or limited product shelves are not unfairly penalized.
- Decision making supports—such as educational tools, alerts, filtering mechanisms, and sample portfolios—should remain permissible when factual, non directive, and accompanied by safeguards.
- SIMA recommends harmonizing terminology across CIRO guidance and IDPC Rules to support consistent compliance.
- SIMA encourages flexibility, innovation, and technology neutral regulation to better serve DIY investors.
- SIMA supports allowing sample portfolios with specific securities, provided disclosures clarify they are not recommendations.
