On March 27, 2025, the Canadian Securities Administrators (CSA) released its 2024 annual report highlighting oversight activities of the Canadian Investment Regulatory Organization (CIRO) and the Canadian Investor Protection Fund (CIPF) in CSA Staff Notice 25-313 2024 Annual Activities Report on the Oversight of Canadian Investment Regulatory Organization and Canadian Investor Protection Fund(the Report).
During the 2024 reporting period, there were five key matters the CSA Member oversight committees focused on:
- Dual registration of CIRO dealer members.This included reviews of potential challenges associated with dual registration of an investment dealer and mutual fund dealer.
- CIRO Rule Book Consolidation (DC Rules).While the first four phases of the DC Rules consolidation have been completed, comments on the proposed rules in the fifth phase ended June 25, 2025. The entire DC Rules will be published in their entirety in 2026 for a final comment period.
- Consolidated fee model applicable to investment dealers and mutual fund dealers.The new fee structure was reviewed to ensure that the proposed fees applied to member firms is proportionate to their registrant activities, with final implementation expected to happen in 2026.
- Registration delegation to CIRO.This review included consideration of the benefits of delegating the registration of investment dealers and mutual fund dealers and those that act on their behalf to CIRO. For more information on this delegation, see BLG's earlier article, Regulators delegate, CIRO regulates.
- Expediting the registration of crypto trading platforms.This included reviewing the intake process of applications to CIRO for new membership requests for crypto-asset trading platforms and business change requests from existing CIRO investment dealers looking to expand their offerings to include the distribution of crypto asset products.
CSA Members also conducted a risk-based oversight review of specific processes in three functional areas of CIRO, namely: trading conduct compliance, membership intake, and information technology. The results of this oversight review will be published in a separate report.
Other high priorities areas for the CSA Member oversight committees included:
- Directed commissions.CIRO is considering how to harmonize the regulatory approach to the payment of compensation to Approved Persons governed by the Mutual Fund Dealer (MFD) Rules and those governed by the IDPC Rules. A position paper was released in 2024 for comment, and it was noted that CSA Members will monitor CIRO's final proposal.
- CIRO/CIPF New Cooperative Operating Agreement.CSA Members will review to ensure that the appropriate governance structure for the investor protection fund is in place.
- CSA Review of Materials Filed by CIRO and CIPF.CIRO and the CIPF are required to file information (beyond proposed rules or by-law amendments) with CSA Members relating to the condition of their respective member firms. During the reporting period, 71 filings were reviewed, 56 filings from CIRO and 15 from CIPF. The topics covered in these filings ranged from early warning reports on financial condition of member firms, advance notification of CIRO publications, progress on compliance examination results, and enforcement matters. CIPF filings were made on risk management, operational reports, and financial statements.
During the reporting period, there were no CIRO member insolvencies where CIPF was involved.
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