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Letter Summary:
The Canadian Investment Regulatory Organization (CIRO) is publishing for comment Phase 1 of its Rule Consolidation Project rule proposals. The Rule Consolidation Project will bring together the two member regulation rule sets currently applicable to investment dealers and to mutual fund dealers into one set of member regulation rules applicable to both categories of CIRO Dealer Members.
The objective of Phase 1 of the Rule Consolidation Project (Phase 1 Proposed DC Rules) is to establish a framework for the development of consolidated rules that will apply to all CIRO Dealer Members. The consolidated member regulation rules will be known as the CIRO Dealer and Consolidated (DC) Rules.
The Phase 1 Proposed DC Rules establish the DC Rules structure, which involves the adoption of:
- rule interpretation provisions,
- definitions of common application throughout the rules,
- rule exemption provisions, and
- general standards of conduct applicable to all activities of the dealer and their employees and Approved Persons.
Overview of the Council’s Comments:
The Canadian Investment Regulatory Organization (CIRO) is publishing for comment Phase 1 of its Rule Consolidation Project rule proposals. The Rule Consolidation Project will bring together the two-member regulation rule sets currently applicable to investment dealers and to mutual fund dealers into one set of member regulation rules applicable to both categories of CIRO Dealer Members.
We acknowledge the challenge facing CIRO in this consolidation project and have found CIRO’s strong commitments to process transparency, clear timelines, and engagement with stakeholders, and attention to detail with respect to drafting concerns,
to be particularly commendable. We are generally supportive of any drafting techniques that assist the reader, and as such, we are in favor of using the positive form where possible. We are also generally in favor of harmonization efforts that lead to better client outcomes and that emphasize client choice, and that are accommodative of a variety of dealer business models, provided investor protection is not compromised.