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During the transitional phase, activities carried out in Québec by mutual fund dealers registered in Québec will remain subject to the provisions of Regulation 31-103 respecting Registration Requirements, Exemptions and Ongoing Registrant Obligations, c. V-1.1, r.10 and the applicable laws of Québec.
CIRO has issued orders exempting, effective January 1, 2023, all mutual fund dealers registered in Québec from the application of its rules to their activities in Québec (except for rules necessary to its smooth functioning), and from having to file an application for exemption or communicate any further information to CIRO.
What to expect, by regulatory topic:
As of July 1, 2025, mutual fund dealers registered in Québec, as well as their Dealing Representatives, should contact CIRO with their registration questions. As per the Autorité des marchés financiers (AMF)’s delegation of powers and duties, CIRO will handle the registration of individuals and dealers, including the chief compliance officers and ultimate designated persons for mutual fund dealers registered in Québec.
Since January 1, 2023, companies wishing to register as mutual fund dealers in Québec have also been required to apply for membership with CIRO. CIRO exempts these companies from the application of its rules to their mutual fund activities in Québec, with the exception of the rules necessary to their smooth functioning.
For files under review as of July 1, 2025, the AMF and CIRO will continue to coordinate their work, particularly with regard to the registration, suspension, or revocation of registration of mutual fund dealers.
Dealing representatives of mutual fund dealers registered in Québec are exempt from CIRO’s continuing education requirements for their activities carried out in Québec. They may instead contact the Chambre de la sécurité financière (“CSF”), which is responsible for regulating continuing education for Dealing Representatives of mutual fund dealers registered in Québec.
As per the AMF’s delegation of powers and duties, CIRO handles the inspection of mutual fund dealers registered in Québec for their activities in Québec.
Complaints and inquiries concerning activities carried out in Québec by mutual fund dealers and their registered representatives continue to be managed by the AMF.
Any complaints or inquiries submitted to CIRO regarding mutual fund activities conducted in Québec will be forwarded to the AMF or the CSF, as applicable.
Québec’s mutual fund dealers do not have to contribute to the Canadian Investor Protection Fund for their activities in Québec. They continue to be required to contribute to the Fonds d’indemnisation des services financiers (financial services compensation fund) for said activities.
The AMF and the CSF continue to conduct investigations and initiate disciplinary proceedings, according to their respective jurisdictions, in respect of activities carried out in Québec by mutual fund dealers and their registered representatives.
Furthermore, the AMF, the CSF and CIRO cooperate in order to maintain regular and effective communications and coordinate their efforts and actions for the enforcement of applicable legislative and regulatory provisions.
CIRO does not charge membership dues to mutual fund dealers registered in Québec, nor to their registered representatives for their activities in Québec.
For services provided to mutual fund dealers in Québec, dues and fees proportional to the services provided apply. The fee schedule for registration applications from individuals acting on behalf of a mutual fund dealer is available at: Fee schedule - Individuals - CEC
CIRO’s provisional rules took effect on January 1, 2023, and allow registered firms to combine their investment dealer activities and their mutual fund dealer activities under one single legal entity. CIRO rules, as well as the legislative and regulatory provisions applicable to mutual fund dealers registered in Québec, including those set out in Regulation 31-103, are applicable to these firms.
Dealing representatives of these firms whose activities are limited to mutual funds fall under the category of Dealing Representative of a Mutual Fund Dealer and must be members of the CSF. For more information, read the FAQ.
The AMF has stated that it is open to receiving applications for exemptive relief from mutual fund dealers, including firms with dual registrations, that would like their mutual fund activities in Québec to be governed by the rules of CIRO, rather than by the equivalent provisions of Regulation 31-103, during the transitional phase. As applicable, the AMF coordinates its actions with CIRO, notably so that the activities of these mutual fund dealers registered in Québec can be supervised primarily by CIRO. If you would like to file an application for exemptive relief, please email: inscription@lautorite.qc.ca.
Mutual fund dealers registered in Québec have had the right to participate as members in CIRO consultations and committee work since January 1, 2023; this includes working on the development of the revised CIRO rules that apply to them following the transitional phase. This allows those mutual fund dealers, including smaller dealers and multidisciplinary firms, to share any specific concerns they may have regarding their own situation and business model, so that the revised CIRO rules may take appropriate account of their concerns.
CIRO’s Regional Council for Québec has set up a mutual funds subcommittee so that Québec’s mutual fund members can participate in regulatory discussions.
If you are interested in sitting on the Mutual Funds Subcommittee, please contact Alexandre Bardoux, Regional Director, Regulation at abardoux@ciro.ca for more information.
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