CIRO proposal to increase annual fees for approved person

Submission – CIRO – Proposed amendment of approved-person fees component within the annual fee of dealer-member fee model

Recipients

Canadian Investment Regulatory Organization (CIRO)

Industry segments this resource supports

• Wealth management

Summary

We responded to CIRO’s proposal to increase the annual fee for approved persons from $250 to $300. While we acknowledge CIRO’s need to avoid operating deficits, we raise concerns about the timing, transparency and duplication of fees across regulatory bodies. The submission urges CIRO and the CSA to collaborate with industry to develop a fee model that is fair, predictable, and aligned with firms’ budgeting cycles. We also highlight operational challenges created by short consultation periods and overlapping registration requirements.

Why this matters: Fair and predictable regulatory fees help firms manage costs effectively so they can continue providing accessible, high quality advice to investors.

Key takeaways

• SIMA disagrees in principle with the proposed fee increase due to its impact on dealers’ budgets and the lack of transparency around how fees are set.
• SIMA does not oppose the amendment outright but stresses that the increase was unexpected and introduced after most firms had finalized their 2026 budgets.
• SIMA calls for better coordination between CIRO and CSA fee structures to avoid duplication and reduce barriers to market participation.
• The 30 day consultation period was too short for stakeholders to provide meaningful feedback.
• SIMA recommends eliminating redundant registration steps when approved persons move between mutual fund and investment dealers and establishing clear service standards for registration.

The submission emphasizes the need for a transparent, sustainable fee model that supports investor access to advice and market efficiency.