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Letter Summary:
CIRO is publishing for comment Phase 2 of its Rule Consolidation Project. The Rule Consolidation Project will bring together the two member regulation rule sets currently applicable to investment dealers (the IDPC Rules) and to mutual fund dealers (the MFD Rules) into one set of member regulation rules applicable to both categories of CIRO Dealer Members. The consolidated member regulation rules will be known as the CIRO Dealer and Consolidated Rules (DC Rules).
The objective of Phase 2 of the Rule Consolidation Project (Phase 2 Proposed DC Rules) is to adopt rules to be retained that are unique to the IDPC or MFD Rules and have been assessed as not having a material impact on stakeholders.
The Phase 2 Proposed DC Rules involve the adoption of rules relating to:
- margin,
- debt markets and Inter-Dealer Bond Brokers, and
- trading.
Overview of the Council’s Comments:
The CAC is generally supportive of CIRO’s rule consolidation efforts that will have the effect of promoting regulatory harmonization and efficiency in regulatory compliance. In particular, they support the proposal to create one uniform financial filing form (Form 1) as considered in Phase 1 of the consolidation project, which will be particularly useful for existing dual-registered dealer entities and also for ease of review.
The CAC would continue to appreciate the inclusion of supporting impact analysis and/or data-driven background relating to the intended purposes of incremental data collection from dealer entities, for a better understanding of the effect on regulatory efficiency and effectiveness, and systemic/macroprudential aspects of securities regulation.