Proficiency model for approved persons under IDPC rules
This submission matters because CIRO’s proposed proficiency model will directly affect the qualifications, training expectations, and regulatory obligations of investment dealers and their registered personnel.
Submission – CIRO – Proposed Proficiency Model – Approved Persons Under the Investment Dealer and Partially Consolidated Rules
Recipients
- Canadian Investment Regulatory Organization (CIRO), Registration, Proficiency
- Ontario Securities Commission (OSC), Trading and Markets
Industry segments this resource supports
- Wealth management
Summary
We submitted comments to CIRO on its proposed proficiency model for Approved Persons under the Investment Dealer and Partially Consolidated Rules. We support CIRO’s objectives to raise proficiency standards, reduce licensing barriers, and improve alignment between regulatory expectations and industry training. However, we highlight several implementation challenges and recommend clearer communication, transitional flexibility, and reconsideration of certain experience requirements. The submission also addresses potential unintended consequences for firms, executives, and individuals transitioning under the new model.
Why this matters: This submission matters because CIRO’s proposed proficiency model will directly affect the qualifications, training expectations, and regulatory obligations of investment dealers and their registered personnel.
Key takeaways
- IFIC supports CIRO’s goals to enhance investor protection, improve market integrity, and modernize proficiency requirements.
- The news release emphasizes that higher proficiency standards will strengthen the investment industry while ensuring continued access to professional advice.
- IFIC urges CIRO to maintain ongoing communication with investment dealers to identify and resolve implementation issues during the transition period.
- The submission raises concerns about administrative burdens, including the risk of inappropriate suspensions if firms fail to report proficiency completion within strict timelines.
- IFIC recommends a minimum 10 business day grace period to prevent unnecessary disruptions for clients and firms.
- IFIC highlights concerns about the proposed experience requirements for Executives and UDPs, noting that overly narrow definitions could limit the pool of qualified candidates.
- IFIC encourages CIRO to consider the relevance of experience gained in mutual fund dealer environments and to avoid unintended barriers to senior level recruitment.
- The submission also addresses transitional provisions, including timelines for CSI course completion and exam validity, recommending adjustments to avoid disadvantaging individuals.
IFIC provides detailed responses to CIRO’s consultation questions in Appendix A.
