Non-tailored advice in the OEO channel

Submission – CIRO – Non-Tailored Advice in the Order Execution Only Channel

Recipients

Canadian Investment Regulatory Organization (CIRO)

Industry segments this resource supports

• Wealth management

Summary

This is a response to CIRO’s consultation on whether OEO dealers should be permitted to provide non-tailored advice to clients. The submission explains that current CIRO guidance restricts OEO dealers from offering recommendations and limits the tools and information they may provide. We note that ambiguity in the guidance has created uncertainty, discouraging dealers from offering helpful tools and information, and pushing many investors toward unregulated sources, such as social media influencers and copy-trading platforms. We support CIRO’s review of the framework and provide detailed recommendations to clarify definitions, expand permitted tools, and ensure investors have access to high-quality, non tailored information without compromising regulatory boundaries.

Why this matters: This submission addresses how order-execution – only (OEO) dealers can provide information and tools to investors without crossing into personalized advice, directly affecting investor protection and market clarity.

Key takeaways

• We support CIRO’s evaluation of whether OEO dealers can provide non tailored advice to better meet investor needs.
• Current OEO guidance lacks clarity, particularly around what constitutes a “recommendation,” creating legal and compliance uncertainty for dealers.
• Restrictions have discouraged OEO dealers from offering helpful tools, alerts, and educational resources, pushing investors toward unregulated sources such as social-media – based “finfluencers.”
• We recommend clarifying the definition of a recommendation, updating the list of permitted tools, and reconsidering the term “non- tailored advice,” suggesting alternatives such as “enhanced information.”
• We support allowing model portfolios referencing specific securities, self-assessment tools, and expanded filtering tools, provided they do not constitute tailored advice.
• The submission emphasizes that decisions to issue alerts or proactive information should rest solely with the dealer, not be encouraged or mandated by CIRO.
• We outline considerations for referral arrangements with finfluencers, stressing due diligence, clear disclosure, and separation of roles.
• We acknowledge potential benefits of copy-trading platforms but highlight the need for appropriate disclosures , conflict management, and adherence to CIRO’s general rules.
• Our position is that clearer rules will help investors access reliable information while maintaining strong investor protection standards.