Proposed amendments: total cost reporting
Firms need clear, consistent cost reporting rules to implement regulatory changes accurately and without unnecessary operational burden.
Submission – CIRO – Enhanced Cost Reporting – Proposed Rule Amendments
Recipients
- Canadian Investment Regulatory Organization (CIRO), Member Regulation Policy
- Ontario Securities Commission (OSC), Trading and Markets
- B.C. Securities Commission (BCSC), Capital Markets Regulation
Industry segments this resource supports
- Wealth management
Summary
This submission responds to CIRO’s request for comment on proposed amendments to enhance cost-reporting requirements for investment dealers and mutual fund dealers. We support total cost reporting (TCR) and CIRO’s objective to substantially harmonize its rules with the Canadian Securities Administrators’ TCR enhancements. We also welcome CIRO’s proposal to use a more efficient process for granting exemptions related to clients’ outside holdings. At the same time, our submission highlights several areas requiring clarification before final rules are published. These include confirming that CIRO’s amendments do not introduce new obligations beyond the CSA’s TCR framework, clarifying the status of existing exemptions for clients’ outside holdings, and ensuring that criteria for future exemptions remain consistent with past practices and are communicated with sufficient advance notice.
Why this matters: Firms need clear, consistent cost reporting rules to implement regulatory changes accurately and without unnecessary operational burden.
Key takeaways
- We support CIRO’s enhanced cost reporting initiative and its alignment with the CSA’s TCR enhancements.
- We emphasize that CIRO should explicitly confirm that no new requirements—such as fund by fund annual cost totals—are being added beyond the CSA’s framework, as these would create significant operational challenges.
- We welcome CIRO’s intention to streamline the exemption process for clients’ outside holdings but request clarity on whether existing exemptions will remain valid or require expansion.
- We urge CIRO to provide substantial advance notice if any exemptions will change so firms can plan and implement necessary system updates.
- We ask CIRO to confirm that the criteria for future exemptions will mirror the grounds and conditions used in similar past exemptions to avoid unnecessary cost and administrative burden.
- We reiterate the importance of transparency and clarity before final rule publication to support effective industry implementation.
