CIRO Annual Priorities for fiscal 2025

This Bulletin summarizes the significant activities and initiatives that the Canadian Investment Regulatory Organization (CIRO) is focused on during our 2025 fiscal year: April 2024 – March 2025 (FY25).

This year’s public priorities build on last year’s priorities and begin the work of realizing CIRO’s three-year Strategic Plan released in April of this year. We continue to focus on maintaining regulatory delivery and operations, and integration, while also starting work on achieving the Strategic Objectives as laid out in our Plan.

A Note on The Strategic Plan

A critical component of our strategic planning process was the consultation conducted with our various stakeholders and that work continues to inform our FY 25 Annual Priorities. CIRO did extensive work to obtain feedback from members and other stakeholders on our current role as a regulator. We wanted to know what could be done to better meet the needs of the investor and the industry for the future.

As a self-regulatory organization, we remain responsive to the ongoing needs of our stakeholders, including through the feedback we receive from our advisory committees (such as the Conduct, Compliance and Legal Advisory Section and the Financial and Operations Advisory Section), regional councils, the Investor Advisory Panel, and membership intake requests. We value these relationships and the input they provide and encourage stakeholders to reach out to ask questions, make inquiries or get items on the agenda and on the radar of CIRO. We continue to stay focused on ensuring that our core work reflects the important elements of what our stakeholders need, while also balancing our public interest mandate. This is also true of how we developed our Annual Priorities.

FY25 Annual Priorities

CIRO undertook a thorough process to establish our priorities, focused on connecting them to our Strategic Objectives. Work has begun on all CIRO’s Strategic Objectives but for the FY25 we will put focus on specific Strategic Objectives. As part of that process, we considered:

• Impact to Members, investors and stakeholders
• Size of the impact measured by rule changes, new information or requests for comment
• How the priorities match to the Year 1 integration priorities
• Balance between regulation delivery and operations, integration and Strategic Objectives

These activities and initiatives continue to build on the foundation of the ongoing delivery of CIRO’s mission to promote healthy capital markets by regulating fairly and effectively so that our investors feel protected and confident investing for their futures. For FY25 CIRO is focused on the following three key areas:

1. Integration

Our integration will support the delivery of our commitments to our stakeholders, including the successful completion of the priorities set out by the Canadian Securities Administrators (CSA). CIRO will continue to deliver on our commitment to the integration in the following ways:

1. Integrated Dealer Fee Model - Complete consultation and be ready to implement for FY26.
2. Complete and implement the new integrated Risk Model to assess risk consistently across all CIRO Dealer Members.
3. Align the objectives, uses, processes and information requested previously under the Investment Dealers Annual Risk Questionnaire (ARQ) and the Mutual Fund Dealers Annual Questionnaire (AQ). Launch a new harmonized risk questionnaire using a new platform to enhance the Dealer Member experience.
4. Finalize and execute the aligned examination program, including the risk-based approach to examinations.
5. Develop a proposal to harmonize Continuing Education regimes.
6. Harmonized Directed Commissions - Continue project to develop proposed rule amendments to expand the group of Approved Persons that are able to conduct activities for their sponsoring Dealer Member through a corporation.
7. Rule Consolidation project:
   1. Phase 3: During the year, we will complete the consultation on the proposed Phase 3 consolidated rules;
   2. Phase 4: During the year, we will publish the proposed Phase 4 consolidated rules for public comment;
   3. Phase 5: During the year, we will substantially complete rule development and advisory committee consultation work on the proposed Phase 5 consolidated rules.
8. Launch CIRO’s examinations of Mutual Fund Dealer firms with activities in Québec. 

2. Regulatory Delivery and Operations

CIRO is committed to the continuous delivery of our mandate and our regulatory delivery and operations, or business as usual, remains a constant priority. Specifically this year we will:

1. Complete the CFR Phase 2 sweep testing, review results with the CSA and initiate the work on a joint final report for publication.
2. Address public comments received on the proposed fully paid lending and financing arrangement rule amendments, make necessary adjustments to the proposed amendments and seek approval to finalize them.
3. Implement Phase 1 of a Public Analytics Data Portal (access to aggregate trading information).
4. Issue a bi-annual survey to all Members to obtain feedback on perception of regulatory effectiveness and efficiency of CIRO.
5. Develop surveillance tools to review OTC trading activity of crypto assets.
6. Update the cybersecurity self-assessment checklist.

3. Strategic Objectives

a. Regulatory Evolution

CIRO must support diverse business models and ensure that the regulations it applies are proportionate to the risks in the business that is being regulated. We need to be an agile regulator that delivers efficient and cost-effective service that reflects investor, dealer and marketplace needs through:

1. Establishing public-facing service standards associated with the processing of Member applications and transaction requests.

b. Investor Research, Education and Protection

CIRO is committed to enhancing the investor perspective in our regulatory activities through input from the Investor Advisory Panel (IAP) and the Office of the Investor’s outreach, engagement and partnerships. Our goal is to understand, inform and protect investors by:

1. Launching our first investor survey which provides the foundation for future investor research initiatives. This survey will continue to support our understanding of Canadian investors and inform our rule making processes.
2. Execute an awareness campaign through social media and other channels to increase awareness of CIRO and CIRO’s resources for Investors.
3. Develop a framework to return disgorged funds collected through disciplinary proceedings to harmed investors including public consultation on the framework.
4. Continue to work with the CSA to develop the regulatory framework for crypto asset platforms including tailored requirements around custody and segregation of crypto assets.
5. Conduct a survey of members on the scope of use of technology and third-parties.

c. Registration and Proficiency

We are committed to streamlining and harmonizing our registration framework and proficiency standards to better support the evolving needs of investors and Dealer Members across Canada. This modernization program will set the stage for a better regime that will ensure suitable and competent registrants and firms, and enable them to leverage the right tools to better serve Canadian investors. CIRO will modernize the registration regime and proficiency standards of registrants by:

1. Complete selection of exam design and delivery service provider(s)
2. Propose rule amendments for assessment-based proficiency models
3. Develop a framework for Mutual Fund Dealers’ registration in Quebec to implement delegation of powers

d. Market Regulation

Supporting healthy capital markets is paramount for CIRO and we are committed to increasing confidence in our markets and our market participants. We are committed to right-sizing market regulation, assessing potential policy changes to address current risks and gaps in the rules framework, and developing rule proposals where appropriate. Through consultation, and stakeholder input, we provide effective and appropriate market regulation that supports and fosters fair and efficient capital markets. In FY25, we will do this by:

1. Proposing appropriate rule amendments to accommodate the unique characteristics and structure of ETFs, recognizing the role of the Authorized Participants and the relationship between the primary and secondary markets.
2. Expanding cross-asset surveillance capabilities though the implementation of interest rate derivatives monitoring.
3. Introducing monitoring for potential CORRA manipulation.

Our priorities for FY25 continue the development of CIRO as a new self-regulatory organization.

As a conduct and prudential regulator, we will continue to take a risk-based approach to business conduct, trading conduct, and financial and operational reviews of CIRO-regulated firms, to ensure they comply with statutory and CIRO requirements, and to encourage a strong culture of compliance. As a market regulator, we will continue to oversee both debt and equity trading in Canada to ensure the integrity of our capital markets.

Our Policy and Compliance teams will continue to strive to deliver timely, relevant, comprehensible and proportionate regulation that minimizes undue impact. Our quarterly Policy Priorities publication is an important way we help Dealer Members, investors and other stakeholders anticipate, plan for and/or comment on our current and upcoming policy initiatives.

In keeping with our oversight role, we will continue to investigate and enforce our rules and hold CIRO-regulated Dealers and individual registrants responsible for their actions through various disciplinary sanctions. For more details on the legacy organizations’ enforcement activities, see CIRO’s enforcement reports.

For more information on CIRO, please visit www.ciro.ca.