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CIRO – Proposal to Harmonize CIRO Continuing Education (CE) Programs

Letter Summary:

The Canadian Investment Regulatory Organization (CIRO) is proposing rule amendments to its continuing education (CE) programs under the Investment Dealer Partial Consolidated (IDPC) Rules and
the Mutual Fund Dealer (MFD) Rules as part of its commitment to developing harmonized Continuing Education (CE) rules.

Overview of the Council’s Comments:

Key Areas of Support and Concern:

• Recordkeeping and Reporting: – The CAC supported a harmonized approach where firms are responsible for recordkeeping.
  • The CAC endorsed a 7-year recordkeeping requirement, aligning with NI 31-103.
• Elimination of Carry-Forwards:
  • The CAC agreed with the removal of carry-forwards to ensure CE remains relevant and up to date.
  • The CAC believed CE should address evolving industry risks and trends.
• Course Repeats:
  • The CAC urged that repeated courses be only accepted in exceptional circumstances, where substantial new content warrants the retake.
  • The CAC urges CIRO to provide clear guidance to firms to prevent the over/misuse of repeated courses.
• Concerns About Accreditation Removal:
  • Without mandatory accreditation, the CAC is concerned that there is a risk of low-quality CE courses being accepted. The CAC recommended CIRO take action to:
    • Promote high-quality, accredited CE providers.
    • Monitor and enforce standards against subpar CE offerings.
    • Issue warnings about unacceptable CE courses or providers.
• Prorating CE Requirements:
  • The CAC supported introducing proration to the IDPC Rules, which would reduce costs and administrative burdens associated with filing exemption requests.
• Aligning the MFD CE Cycle with the Calendar Year (Jan 1 – Dec 31):
  • The CAC supported harmonization for consistency.
• Shifting to an Annual CE Cycle:
  • The CAC supported an annual CE cycle for firms and Approved Persons, which would align with international best practices and ensure CE remains current.
  • The CAC believes this change is necessary given the fast-evolving nature of the industry