Strengthening CIRO’s proposed integrated fee model

Submission – CIRO Consultation Re: Proposed Integrated Fee Model

Recipients

• Canadian Investment Regulatory Organization (CIRO)

Industry segments this resource supports

• Wealth management

Summary

Our submission responds to CIRO’s proposed integrated fee model, which would calculate fees based on firm revenue and the number of approved persons. While we support the overall direction of the model, we raise concerns about the likelihood of fee increases for the majority of registrants, the lack of transparency in CIRO’s cost-recovery modeling, and the need for clearer definitions of revenue and approved persons. The submission also highlights the industry’s expectation that CIRO’s creation would reduce duplicative regulatory costs and lead to fee reductions, not increases.

Why this matters: CIRO’s proposed fee model could significantly increase regulatory costs for most registrants, affecting firms and the investors they serve.

Key takeaways

• IFIC agrees with the general structure of the proposed fee model but identifies four areas requiring revision before finalization.
• According to CIRO’s own estimates, 64% of registrants are likely to see fee increases, while only 36% may see reductions.
• IFIC notes that the industry expected CIRO’s formation to generate efficiencies and cost savings, making the projected fee increases inconsistent with earlier commitments.
• The submission emphasizes that CIRO has not provided sufficient data or modeling details to justify the proposed fee structure or allow stakeholders to assess its impact.
• IFIC requests a review of the definitions of “revenue” and “approved persons,” arguing that certain revenue types and non–client-facing roles should not be included in fee calculations.
• Concerns are raised about potential duplication of regulatory fees in Quebec, where AMF and CSF fees already apply.
• IFIC recommends a second consultation once CIRO provides full data transparency and modeling details.