CIRO rule-consolidation project phase 4
Consolidated CIRO rules will directly shape how investment dealers and mutual fund dealers operate, comply, and support clients under a unified regulatory framework.
Submission – CIRO – CIRO Rule Consolidation Project – Phase 4
Recipients
- Canadian Investment Regulatory Organization (CIRO), Member Regulation Policy
- Ontario Securities Commission (OSC), Trading and Markets division
- BC Securities Commission (BCSC), Capital Markets Regulation division
Industry segments this resource supports
- Wealth management
Summary
This submission reaffirms our support for CIRO’s efforts to merge the two existing rulebooks for investment dealers and mutual fund dealers into a single, comprehensive set of CIRO dealer and consolidated (DC) rules. The submission emphasizes the importance of clarity, consistency, and efficiency in the development and implementation of the new rules. We commend CIRO for adopting several recommendations from earlier phases, including extending consultation periods, committing to publish aggregated rules for review, and confirming that the DC rules will be implemented as one complete package rather than in stages. The submission reiterates our guiding principles from earlier phases and requests that CIRO develop and publicly consult on updated guidance before the final rules come into force.
Why this matters: Consolidated CIRO rules will directly shape how investment dealers and mutual fund dealers operate, comply, and support clients under a unified regulatory framework.
Key takeaways
- We fully support CIRO’s rule-consolidation initiative and continue to apply its guiding principles from Phases 1–3 to assess Phase 4 proposals.
- CIRO has adopted several IFIC recommendations, including extending the stakeholder comment period for Phases 4 and 5 from 60 to 90 days.
- CIRO has agreed to publish and aggregate the proposed DC rules for final review and comment, improving transparency and enabling more effective industry feedback.
- CIRO has confirmed that the DC rules will be implemented as a single, comprehensive set of rules rather than through phased implementation.
- These decisions will give industry members the time needed to assess Phase 5 proposals and the final DC rules in a meaningful way.
- We stress the need for an appropriate transition period once the DC rules are finalized so firms can update policies, procedures, IT systems, and training.
- We reiterate the importance of CIRO developing and consulting on updated guidance to accompany the final DC rules, rather than relying on legacy guidance.
- We provide detailed responses to CIRO’s consultation questions, including support for the revised definition of “investment product,” considerations about governance requirements, and the need for consistent approaches to risk-rating changes.
