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Consultation Paper – Proposed Proficiency Model – Approved Persons under the Investment Dealer and Partially Consolidated Rules (the “Consultation”)

Letter Summary:

Over the last few years, the Canadian Investment Regulatory Organization (CIRO), through its predecessor organization, the Investment Industry Regulatory Organization of Canada (IIROC), has undertaken a multi-year initiative to enhance its proficiency regime with the intention of launching the new standards in 2026. Proficiency standards are a cornerstone of the CIRO regulatory regime. High proficiency standards play a key role in investor protection and the integrity and efficiency of capital markets. CIRO’s goal is to create, maintain and promote high proficiency standards and a robust proficiency regime in the investment industry.

As part of this initiative, CIRO is seeking feedback on its proposed proficiency model. CIRO is proposing the proficiency model shift from a course centric model with exams tied to courses, to an assessment centric model with some mandatory education and training.

Overview of the Council’s Comments:

We are open to supporting the model proposed in the Consultation, in particular to the extent it aligns with the U.S model adopted by FINRA and the requirement for exam takers to have a sponsoring firm. We have concerns that many of the specific details of the operational and governance structures surrounding the proposed proficiency model are where potential issues of concern may arise. As such, we would welcome further details for review and comment, including more explicit details on the content structure and standards to which candidates will be held, the levels of transparency which will be provided on the operation and governance of the model, exam content, and examination standards.