CIRO rule-consolidation project phase 3
Outlines industry recommendations to ensure CIRO’s consolidated rulebook is implemented efficiently, consistently, and without unnecessary regulatory or operational burden.
Submission – CIRO – CIRO Consultation Phase 3
Recipients
Canadian Investment Regulatory Organization (CIRO)
Member Regulation Policy
Industry segments this resource supports
- Wealth management
Summary
We submitted comments on Phase 3 of CIRO’s Rule-Consolidation Project, providing feedback on proposed changes to the Dealer and Consolidated Rules (DC Rules). The submission emphasizes the need for a cohesive, simultaneous implementation of all phases, sufficient transition time for firms, and improvements to CIRO’s consultation processes. It also outlines guiding principles for rule development, including regulatory consistency, flexibility, and proportionality across dealer types. The submission includes responses to CIRO’s eight consultation questions and recommendations on guidance, implementation timelines, and operational impacts.
Why this matters: Outlines industry recommendations to ensure CIRO’s consolidated rulebook is implemented efficiently, consistently, and without unnecessary regulatory or operational burden.
Key takeaways
- IFIC reiterates its guiding principles for rule consolidation, including minimizing regulatory arbitrage, ensuring consistent oversight, and maintaining flexibility for different dealer business models.
- IFIC urges CIRO to publish the full, final DC Rules only after Phase 5, allowing members to review the complete rulebook and provide informed feedback.
- IFIC strongly recommends simultaneous implementation of all phases to avoid duplication, reduce implementation risk, and prevent client confusion.
- The submission highlights the significant operational, IT, compliance, and training impacts of the project and stresses the need for a sufficient implementation period.
- IFIC requests that CIRO adopt a minimum 90 day comment period for all future consultations, noting the increasing complexity and overlapping timelines of regulatory proposals.
- IFIC recommends that CIRO undertake a public consultation process to update and consolidate guidance for the final DC Rules, rather than simply adapting existing interim guidance.
The submission includes detailed responses to CIRO’s eight consultation questions, covering topics such as business premises, business continuity plans, maximum fines, arbitration, and bulk transfers.
