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CIRO Bulletin 26-0089 — Proposal to Harmonize CIRO Continuing Education Programs — Phase 2
Letter Summary
CIRO is consulting on the second phase of proposals to finalize harmonization of continuing-education program requirements under the Investment Dealer and Partially Consolidated (IDPC) Rules and the Mutual Fund Dealer (MFD) Rules. Phase 2 covers CE credit requirements, the population of Approved Persons subject to CE, definitions and vocabulary, automatic suspension and reinstatement, cycles, proration, leaves of absence, exemptions, mandatory accreditation assessments, examination-based CE, prohibitions on carry-forwards, reporting for terminated individuals, compliance-manual training, and treatment of Mandatory Conduct Training as CE
Overview of the Council’s comments:
The CAC supported CIRO’s Phase 2 CE harmonization proposals, including calendar-year cycle alignment, proration, harmonized definitions, extended reporting timelines, the shift from “credits” to “hours,” and expanded CE requirements for senior executives. However, the CAC cautioned that the framework appeared too focused on reducing burden and did not sufficiently replace eliminated accreditation, audit, and topic-list mechanisms with new quality safeguards. The CAC recommended recurring CIRO-developed CE content, guidance on appropriate CE by registration category, and mechanisms to verify participant understanding. It also urged CIRO to add firm-level accountability for systemic CE failures and to preserve CE compliance status at departure through NRD rather than eliminating terminated-individual reporting.