CIRO Interim Rules – Frequently Asked Questions

Updated on: September 5, 2025

Introduction

The responses to these FAQs are based on the currently drafted interim rules for CIRO (interim rules) and are intended to address a range of Member situations. The interim rules may not apply if there are subsequent changes or amendments to these rules.

Members are encouraged to contact CIRO staff for clarification on how the interim rules may apply to their specific circumstances.

General changes

1. Why are there CIRO interim rules?

To ensure minimal disruption to members and their employees and Approved Persons, each set of IIROC and MFDA Rules has been adopted by CIRO and will continue to apply with some key rule changes proposed in the interim to address structural impediments to the industry.

The CIRO interim rules are comprised of the following rule sets:

1. the Investment Dealer and Partially Consolidated Rules1,
2. the Universal Market Integrity Rules, and
3. the Mutual Fund Dealer Rules.

2. When will there be a consolidated rule book?

CIRO is currently focused on consolidating the Investment Dealer and Partially Consolidated Rules with the Mutual Fund Dealer Rules. We will provide regular updates on the plan and progress throughout the process. Members can track the status of the Rule Consolidation Project on the CIRO website.

To clarify, the Universal Market Integrity Rules are excluded from the consolidation plan.

3. What are the key changes in the interim rules?

The rule changes included in the interim rules (mainly within the Investment Dealer and Partially Consolidated Rules) are intended to:

1. eliminate IIROC District Council regulatory approval authorities while maintaining their advisory role,
2. permit mutual fund dealers to introduce business to investment dealers, enabling greater mutual fund dealer client access to exchange traded funds,
3. give mutual funds only registered individuals employed by firms registered as both investment dealer and mutual fund dealer (dual-registered firms) the option of conducting business primarily within the Investment Dealer and Partially Consolidated Rules on a permanent basis,
4. permit mutual-funds-only registered individuals, retained or contracted as agents by a dual-registered firm, to be able to direct commissions to an unregistered corporation, where permitted by local securities legislation, provided they are not in the process of upgrading their proficiencies to those of a securities licensed individual2,
5. facilitate the timely movement of accounts between affiliated firms (including situations where accounts are being moved to a dual-registered Affiliated Firm) without requiring the completion of new account documentation, under certain conditions, and
6. allow for a sufficient Dealer Member implementation period to make changes to membership disclosure for the names of CIRO and the investor protection fund.

Conducting mutual fund business and investment dealer business within the same legal entity (dual-registered firms)

4. What kinds of exemptive relief will CIRO consider for dual-registered firms?

To assist mutual fund dealers with their transition to a dual-registered firm, either by adding investment dealer registration (alongside the existing mutual fund dealer registration) or amalgamating with another investment dealer, CIRO will consider granting exemptive relief from certain Investment Dealer and Partially Consolidated Rules so that the mutual fund dealer division and operations of the dual-registered firm can continue as they do today. Any exemptive relief from the Investment Dealer and Partially Consolidated Rules granted to a dual-registered firm’s mutual fund division will expire upon the implementation of CIRO Dealer and Consolidated Rules.

Please see the attached for examples of exemptions granted to dual‑registered firms in 2023 and 2024:

• Rules Bulletin 25-0187, section 2.2
• Rules Bulletin 24-0345, section 2.1

5. My firm is a mutual fund dealer with no investment dealer affiliate. What additional information would the firm need to provide to CIRO to be approved as a dual-registered firm?

For details on the process of becoming a dual-registered firm, please refer to the following resources:

• Becoming a Dual-Registered Firm
• Dual-Registration Questionnaire for Existing Members
• Dual-Registration Documentation Checklist

6. My firm is an investment dealer with no investment dealer affiliate. What additional information would the firm need to provide to CIRO to be approved as a dual-registered firm?

For details on the process of becoming a dual-registered firm, please refer to the following resources:

• Becoming a Dual-Registered Firm
• Dual-Registration Questionnaire for Existing Members
• Dual-Registration Documentation Checklist

Introducing Broker/Carrying Broker Arrangements

7. What changes have been made to the Introducing Broker/Carrying Broker Arrangements in the interim rules?

Under current MFDA Rules, a MFDA member may only enter an introducing broker/carrying broker arrangement with another MFDA member. Similarly, under the IIROC rules, an IIROC member may only enter an introducing broker/carrying broker arrangement with another IIROC member. The interim rules have been amended to permit mutual fund dealers to introduce to investment dealers.

8. What business can a mutual fund dealer member introduce to an investment dealer member?

Under the revised interim rules, a mutual fund dealer member can introduce all or any part of its business to an investment dealer member. The services provided by the investment dealer carrying broker may include order execution, clearing and settlement, custody of funds and securities and maintenance of books and records.

9. Which Rules (mutual fund dealer member or investment dealer member Rules) apply to the mutual fund introducing dealer?

A mutual fund dealer member still, primarily, operating as a mutual fund dealer will generally be subject to the Mutual Fund Dealer Rules. The only exception is where, for a particular activity, compliance by one introduction arrangement party to one set of Interim Rule requirements3 interferes with the ability of the other arrangement party to comply with a different set of Interim Rule requirements4 – in this case, both parties must seek exemptive relief from CIRO that specifies the manner in which the activity must be performed and the rule requirements that apply.

10. What is the approval process for new Introducer Broker/Carrying Broker Arrangements?

As is currently required under Mutual Fund Dealer and Investment Dealer Rules, new Introducing Broker/Carrying Broker Arrangements (including the form of agreement) and any amendment to or termination of the arrangement or agreement must be approved by CIRO staff before it is to be effective.

11. What agreement needs to be signed between a mutual fund dealer introducing broker and an investment dealer carrying broker?

There is no standard form agreement that is prescribed for mutual fund dealers who wish to enter into introduction arrangements with investment dealers. However, the agreement must be approved by CIRO and include provisions that address, at a minimum:

• Services being provided by the investment dealer carrying broker to the mutual fund dealer
• Regulatory responsibilities of the parties including responsibilities for compliance, supervision, etc.
• Client reporting requirements
• Disclosures to clients on the relationship between the parties
• Minimum notice of termination timelines and clauses.

The introducing/carrying agreement between the mutual fund dealer and the investment dealer is not considered valid or effective until it receives formal approval from CIRO. Additionally, as CIRO continues to consolidate and harmonize its rulebooks, any inconsistencies or conflicts between the agreement’s terms and CIRO’s rules and requirements will be resolved in favor of the CIRO rules.

Registration/ Approval Changes

12. Where can dealers find more information on registered individual and the approval process?

For more information on registered individuals and approval changes, please visit: For Registered Individuals.

Québec considerations

13. What are the implications for all Mutual Fund Dealers registered in Québec? What rules are they subject to on Day 1?

Mutual Fund Dealers registered in Québec became deemed members of CIRO on Day 1. During the transitional period, they continue to be subject to Regulation 31-103 for their activities in Québec and to avoid regulatory duplication, they are not required to comply with CIRO Rules, with the exception of provisions required to ensure the smooth operation of CIRO and to allow MFDs registered in Québec to participate as members in the consultations of CIRO and on the committees that it shall create. CIRO granted exemptions to such Mutual Fund Dealers from compliance with the specified CIRO rules and requirements until the transitional period ends.

CIRO interim rules apply to the activities outside Québec of mutual fund dealers who are registered in Québec and other provinces/territories and Regulation 31-103 will continue to apply to their activities within Québec for the transitional period, as specified above. CIRO will continue to work cooperatively with the Autorité des marchés financiers (AMF) to oversee Mutual Fund Dealers who are registered in Québec and other provinces/territories.

14. Who will be performing the inspections for mutual fund dealers registered in Québec?

Since September 2024, CIRO has handled the inspection of mutual fund dealers registered in Québec for their activities in Québec, as per the AMF’s delegation of powers and duties. CIRO will continue to perform the inspections for the rest of the transitional period. For more information on the transitional phase, please visit the Quebec mutual fund dealer members webpage.

15. Who will be in charge of enforcement proceedings?

1. Mutual Fund Dealers who are only registered in Québec
   
   Mutual Fund Dealers who are only registered in Québec will continue to be subject to enforcement proceedings by the AMF for dealers and their executives. For their registered representatives, the CSF will continue to be in charge of enforcement proceedings.
2. Mutual Fund Dealers who are registered in Québec and other provinces/territories
   
   For activities in Québec, the AMF will continue to be in charge of enforcement proceedings for the dealers and their executives. For activities outside of Québec, CIRO will continue to oversee enforcement proceedings for dealers and their executives. For their registered representatives, the CSF in Québec and CIRO outside Québec will continue to be in charge of their respective enforcement proceedings.
3. Mutual Fund business of dual-registered firms who are registered in Québec and other provinces/territories
   
   CIRO will oversee enforcement proceedings for all dealers and their executives at dual-registered firms. For the mutual fund dealing representatives registered in Québec, the CSF will be in charge of the enforcement proceedings.

16. How will the AMF, the CSF and CIRO coordinate the application of their respective Enforcement decisions?

The AMF and the CSF will inform CIRO of their respective enforcement decisions, allowing CIRO to take the appropriate measures. The AMF, CSF and CIRO will enter into a Memorandum of Understanding that will allow them to collaborate and coordinate regarding Enforcement decisions and other activities, where applicable.

17. Will dealing representatives of mutual fund dealers registered in Québec be required to become approved persons of CIRO, for their activities in Québec?

No. Dealing representatives of Mutual Fund Dealers registered in Québec will only be required to register with the AMF, for their activities in Québec.

Fees

18. Where can I find details regarding CIRO’s Integrated Fee Model?

For more information on the Integrated Fee Model, please visit the Integrated Fee Model webpage.

• 1The title of this rule set has been changed from “IIROC Rules” to “Investment Dealer and Partially Consolidated Rules” to clarify that these interim rules:
  • in most areas only apply to investment dealers and, where applicable, their employees and Approved Persons
  • in certain areas:
    • apply to both investment dealer and marketplace Regulated Persons, including investment dealers and their employees and Approved Persons
    • represent partially consolidated rules of CIRO that apply to both investment dealer and marketplace Regulated Persons, including persons subject to the Universal Market Integrity Rules (UMIR), but do not apply to mutual fund dealer Regulated Persons, including their employees and Approved Persons.
• 2Mutual fund dealer representatives with a firm that is only registered as a mutual fund dealer will continue to be able to direct commissions in accordance with Mutual Fund Dealer Rule 2.4.1(b).
• 3Such as the mutual fund dealer introducing broker complying with mutual fund dealer rule requirements for a particular activity.
• 4Such as the investment dealer carrying broker complying with investment dealer rule requirements for a particular activity.