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CIRO – Bulletin 26-0040 – Proposed Dual Registration Requirements – Proposed CIRO Rules
Letter Summary
CIRO is seeking comment on amendments to its Proposed CIRO Rules that would retire the dual registration framework. The changes would remove proficiency upgrade requirements for mutual fund-only advisors at Investment Dealer Members and formalize the exemptive relief conditions currently used by dual-registered firms. The goal is to simplify registration requirements and create a more consistent framework for all Dealer Members.
Overview of the Council’s comments:
The CAC broadly supported CIRO’s proposed dual registration amendments, noting that allowing Investment Dealer Members to operate mutual fund divisions under a single registration would reduce duplication and align with the broader consolidation of dealer regulation. However, the CAC stated that true regulatory unification required modernization of proficiency and conduct standards for mutual fund-only Approved Persons. The CAC recommended that CIRO and the CSA develop integrated proficiency baselines using CIRO’s competency-profile and assessment-centric approach, including mandatory conduct training. The CAC also encouraged CIRO to provide more quantitative impact analysis in future consultations.