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This summer, the Canadian Investment Regulatory Organization (CIRO) published amendments to the Mutual Fund Dealer Rules and the Investment Dealer and Partially Consolidated Rules intended to implement the Total Cost Reporting (TCR) Enhancements contained in National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Requirements. The amendments will be effective on January 1, 2026, and will mandate enhanced transparency of investment fund costs and ensure regulatory alignment to the changes already finalized by the Canadian Securities Administrators.
Dealers will be required to report in the annual fee/charges report to clients for the account for all investment fund securities owned by the client during the reporting period a significant amount of new, or enhanced, information. The amendments also specify the method for calculating the aggregate amount of fund expenses, expands the notifications in the annual fee/charges report, clarifies dealer responsibility with regards to the reportable fee information and use of reasonable approximations, and provides for reporting exemptions.
The notice indicated that CIRO staff will consider dealer requests for exemptions from the quarterly and the annual reporting requirements with regards to client outside holdings (client name) positions in the enumerated circumstances. CIRO also published an Exemption Application (Outside Holdings) form to be used by member firms making a new application or seeking an extension of an existing exemption regarding the reporting of fees and charges related to outside holdings.
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