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31 December 2025

Tapping Into Trouble: CSA Phase 2 CFR Sweep Results

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Borden Ladner Gervais LLP

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BLG is a leading, national, full-service Canadian law firm focusing on business law, commercial litigation, and intellectual property solutions for our clients. BLG is one of the country’s largest law firms with more than 750 lawyers, intellectual property agents and other professionals in five cities across Canada.
The Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) have released their much-anticipated Client Focused Reforms (CFR) Phase 2 Sweep Report...
Canada Corporate/Commercial Law
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The Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) have released their much-anticipated Client Focused Reforms (CFR) Phase 2 Sweep Report, which provides additional and, in some cases, expanded, guidance with respect to KYC, KYP and suitability obligations. This joint report summarizes the CSA and CIRO findings on their sweep and provides actionable recommendations on core registrant obligations, including product due diligence, assessing risk and the process for recommending alternative investment products.

As this guidance will impact all registered firms, BLG has released a separate Insight summarizing the material features of the guidance and referencing the webinar BLG will be hosting to provide additional insights and views on the report, entitled "Under the bright lights: CSA & CIRO illuminate enhanced expectations in phase 2 client-focused reform sweep"

We can assist with updating your policies and procedures, reviewing client facing documentation and providing training to your employees. Please contact us with any questions on this report.

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