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CIRO Bulletin 26-0039 – Rule Consolidation Project
Letter Summary
CIRO is seeking comments on Phase 6 of its Rule Consolidation Project, which would bring the rules for Investment Dealers and Mutual Fund Dealers into one harmonized rulebook, to be known as the CIRO Rules. The proposed changes aim to reduce regulatory arbitrage, improve clarity, and create more scalable, principles-based requirements across dealer business models.
Key updates include revisions to proficiency requirements, complaint handling, cybersecurity incident reporting, electronic delivery of client documents, Form 1 reporting, and implementation timelines.
Overview of the Council’s comments:
The CAC supported CIRO’s Rule Consolidation Project and its move toward harmonized, principles-based regulation across Investment Dealers and Mutual Fund Dealers. Its main concern was that Rule 3700’s reporting, investigation, and complaint handling requirements could be applied inconsistently unless CIRO issued interpretive guidance before or when the rules take effect. The CAC supported competency-based supervisor proficiency requirements and did not identify implementation impacts that would prevent Mutual Fund Dealer Members from complying on time. It also recommended a post-implementation review 18 to 24 months after implementation to assess consistency, operational impacts, and whether the rules were achieving their objectives.