Delivery of documents during a postal strike or lockout

A nationwide postal strike or lockout may occur as early as May 22, 2025. In the event of such postal strike or lockout, Dealer Members must:

• avoid use of the postal service where its use has been determined to be unreliable
• ensure they continue to comply with the document delivery requirements prescribed under CIRO Rules, and other applicable requirements
• ensure that the document delivery options they use during the course of the postal service disruption do not unduly negatively impact clients or represent conduct that is “…unbecoming or detrimental to the public interest”1.

Where the Dealer Member chooses to instead deliver documents through the use of an electronic communications method, Dealer Members are encouraged to review the requirements set out in National Policy 11-201 – Electronic Delivery of Documents (NP 11-201), and, as necessary, to consult with the various CSA member jurisdictions for any local requirements that might apply.

Specific CIRO recommendations

If there is a postal strike or lockout, we recommend Dealer Members take the following specific actions:

1. Advise your clients:
   • there could be a delay in receiving documents recently sent to them through the postal service and that these documents can be resent using an alternative document delivery option if the client requests
   • of the alternative document delivery options you are making available to them during the course of the service disruption.
2. Inform your client-facing Approved Persons of the alternative document delivery options you are making available to clients. During any client discussions have the client confirm (or reconfirm) which of these alternative document delivery options they would like to use during the course of the service disruption.
3. For time sensitive or important deliveries that can’t be facilitated electronically (including those that relate to the account transactions or the movement of client funds or investment product positions or entire accounts), Dealer Members should strongly consider the use of courier delivery2 to ensure timely delivery to clients directly or to branch offices for client pickup.
4. For all other deliveries:
   • provide your clients with the opportunity to receive documents by email3 or fax.
   • where clients do not have these services, where practical, consider courier delivery to clients directly or to branch offices for client pickup or other alternatives.
5. Remind your client-facing Approved Persons to confirm trades and communicate cash and margin calls by telephone and to use these calls as an opportunity to confirm (or reconfirm) the client’s chosen alternative document delivery option during the course of the service disruption.

• 1Investment Dealer and Partially Consolidated Rule clause 1402(1)(i) and Mutual Fund Dealer Rule 2.1.1(c).
• 2Courier delivery includes private couriers, such as bike couriers and commercial couriers, such as FedEx, Purolator and UPS. Interoffice mail can also be considered a delivery option when sending documents to branches for client pick-up.
• 3Email includes an email to a client’s personal email address and emails delivered to a client through an electronic document delivery system, provided the practice complies with applicable securities regulations.