CIRO Embarks on Phase 3 of its Rule Consolidation Project and Proposes Integrated Fee Model

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The Canadian Investment Regulatory Organization (“CIRO”) recently published for comment proposals relating to Phase 3 of its rule consolidation project (the “Rule Consolidation Project”) as well as a new integrated fee model (the “Fee Model”) for investment dealers and mutual fund dealers.

Rule Consolidation Project

As we discussed in a previous post, the purpose of the Rule Consolidation Project is to bring together the rules currently applicable to investment dealers and mutual fund dealers into one set of rules applicable to both categories of CIRO dealer members. While Phase 1 set out a structure for the consolidated rules, Phase 2 proposals related to margin, debt markets and inter-dealer bond brokers and trading.

The Phase 3 proposals involve: (i) membership and member business activity approval matters; (ii) clearing and settlement of trades and trade delivery standards; and (iii) examination, investigation and enforcement rules.

CIRO is accepting comments on the proposed rules until July 17, 2024. For more information, see CIRO Bulletin 24-0145 Rule Consolidation Project - Phase 3.

Fee Model

The Fee Model, which is expected to be effective as of April 1, 2025, is intended to replace the Interim Fee Model Guidelines Applicable to Investment Dealer Members and Marketplace Members and the Interim Fee Model Guidelines for Mutual Fund Dealers. The objective is to implement a consistent and harmonized approach to cost recovery for dealer regulation that can be applied to all CIRO dealer members.

CIRO is accepting comments on the Fee Model until June 24, 2024. For more information, see CIRO Bulletin 24-0154 Proposed Integrated Fee Model.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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