Advancing a consolidated rule framework for dealers
CIRO’s rule-consolidation will shape how dealers operate and how consistently rules are applied across the investment industry.
Submission to CIRO – RE: CIRO Rule Consolidation Project – Phase 2
Recipients
- Member Regulation Policy, Canadian Investment Regulatory Organization (CIRO)
- cc: Market Regulation, Ontario Securities Commission
- cc: Capital Markets Regulation, B.C. Securities Commission
Industry segments this resource supports
- Wealth management
Summary
Our submission provides feedback on Phase 2 of CIRO’s rule-consolidation project, which aims to merge the existing Investment Dealer and Mutual Fund Dealer rules into a single, unified framework. We reiterate our guiding principles for evaluating the project and emphasize the need for all phases to be implemented concurrently to avoid duplication, reduce implementation risk, and ensure clarity for clients and dealers. The submission also offers recommendations to improve the consultation process and includes detailed responses to CIRO’s questions on best execution, debt market trading and settlement practices, and transaction reporting for debt securities.
Why this matters: This submission matters because CIRO’s rule-consolidation will shape how dealers operate and how consistently rules are applied across the investment industry.
Key takeaways
- IFIC supports CIRO’s rule-consolidation initiative and the goal of harmonizing requirements across dealer types.
- IFIC stresses that all phases should come into force at the same time to avoid repeated system changes, client confusion, and unnecessary costs.
- Members require a sufficient implementation period to update IT systems, policies, procedures, training, and operational processes.
- IFIC recommends minimum 90 day consultation periods for future phases, noting that overlapping consultations and seasonal timing create challenges for member review.
- IFIC requests clearer descriptions of changes from current MFDA rules to help stakeholders efficiently assess impacts.
- The submission highlights the risk of inconsistent rule interpretation if implementation is rushed or fragmented.
In Appendix A, IFIC responds to CIRO’s questions on best execution, operational impacts for mutual fund dealers dealing in ETFs and debt securities, and the types of implementation support CIRO should provide.
