ComSet Reporting Requirements

Following the transition of mutual fund Dealer Members to reporting complaints and other events using the Complaints and Settlement Reporting System (ComSet), CIRO is providing the following guidance for all CIRO Dealer Members. This Guidance Notice replaces Administrative Bulletin 11-0142 previously issued by the Investment Industry Regulatory Organization of Canada.

Effective November 1, 2025, all Dealer Members are required to attach relevant supporting documentation and provide additional information at the time of initial entry of the ComSet event or thereafter as it becomes available. The documents and information required to be submitted are described in the Summary of Documentation Required by Event Type table below. Providing the documents and information will allow CIRO staff to conduct more timely and efficient reviews of ComSet filings. It is also expected to result in fewer requests by CIRO staff for additional information.

Dealer Members’ general reporting requirements to CIRO under MFD Rules 1.4 and 600, and IDPC Rule 3703 remain the same.

The requirement to attach the supporting documents and provide the information described below applies to events filed or modified after November 1, 2025. ComSet events filed prior to November 1, 2025 do not need to be updated to comply with the requirements described in this Notice unless the event is modified on or after November 1, 2025.

Summary of Documentation Required by Event Type

*Note: These documents are to be attached upon conclusion of the ComSet event or as soon as they are available.

**Please provide a copy of the NCAF/KYC at the time of the initial ComSet entry. If these are separate documents, please include both as we require all client information (including contact information, date of birth, etc.) plus KYC information. If the Dealer Member is unable to upload the NCAF/KYC along with the complaint letter, a note should be made in the comments section of the ComSet record indicating that the NCAF/KYC is forthcoming and will be uploaded when obtained.

ComSet Reporting Requirements Frequently Asked Questions

1. Are service complaints reportable on ComSet?

No. A service complaint is one which is about customer service issues and is not the subject of domestic or foreign securities laws. If a matter involves any potential rule violations it must be reported to ComSet.

2. Is a transfer complaint reportable?

Yes. Transfer complaints are generally considered reportable complaints as they are subject to CIRO Rules. (IDPC Rule 4800, MFD Rule 2.12)

3. Can I use “Other” as a violation type?

Always use the most appropriate violation type. “Other” should only be used if there is no other option available from the drop-down menu. Please provide further details about the nature and details of the complaint in the description field of the “Primary Violation” and, if more details are needed, the “Member comments” section.

4. Do I need to input the “Document Type” when uploading documents to the ComSet record?

Yes. Please ensure that the correct Document Type is selected for the uploaded document.

5. What if the client’s address has changed and no longer matches the address indicated on the NCAF?

The Dealer Member should upload an NCAF/KYC document with the latest address or a change of address document reflecting the client’s current address.

6. What if the NCAF/KYC is not available at the time the ComSet event is created?

Make a note in the “Member comments” section indicating this and that a copy will be uploaded once retrieved.

7. I created a ComSet record for the Firm instead of the Approved Person. Can I update the ComSet event?

No. A new ComSet event will need to be created and the previous ComSet deleted. To delete a ComSet record, please contact ComSet@CIRO.ca. Please ensure to provide an explanation outlining why the ComSet event needs to be deleted, and what the replacement event is, if applicable.

8. We received a complaint from a husband and wife. How many ComSet events need to be filed?

It is only necessary to create one ComSet event if the complaint allegations are substantively the same. You can add multiple clients/accounts in the “Client” section.

9. The client filed a complaint and then subsequently filed a civil claim. Is there any way to link events in ComSet?

Yes, you can link events by clicking on the +Add button under “Related Events”.

10. I am having difficulty uploading documents to the ComSet record. What can I do?

ComSet document attachments must be uploaded in .PDF format and are subject to file naming restrictions (only letters, numbers or hyphens). If you are still having difficulties, please contact ComSet@CIRO.ca.

11. For a customer complaint, why am I not able to enter the client’s date of birth in the Client section of the ComSet record?

Check to see that you selected the appropriate “Client Description” option (Individual). A client’s date of birth does not appear in the “Corporation” option; it only populates when the “Individual” client description is selected.

12. Do I need to enter a separate internal investigation (or termination, etc.) following the review of a previously reported event (such as a customer complaint)?

Generally, no, but you must update the “status detail”, “findings” and “disciplinary actions” sections of the event and attach any relevant documents. If an event, such as a customer complaint, leads to an internal investigation of a much broader scope or an entirely unrelated matter, then yes, you should open a separate “internal investigation” event.

13. Do I need to continue to update an event after we have concluded the matter?

Yes. An example would be where you have denied a complaint, but the complainant has proceeded to OBSI or arbitration. In those cases, you must update the ComSet event “status detail” with the relevant information and upon conclusion, you must update any other relevant information, such as “settlement amount”, “finding”, or “disciplinary action”. If you have already concluded the event, you may use the “edit” feature in the event to make changes. If you have already locked the event, you must first reopen the event to make any edits.

14. How much information should I add to a ComSet event?

A detailed summary of the event in question (under “Member comments”), particularly if the attached documents do not provide sufficient information, is important. You should also complete all fields in the event, if they are applicable.

15. If a reportable matter involves multiple Approved Persons, or the firm and the dealer, do I need to file an event for each?

Yes. Unless in the case of multiple APs, it is initially established that only one AP was directly involved. Example, a client complaint about an advisory team, but one AP dealt with the clients exclusively.

16. Should I file multiple events for the same matter?

Generally, no. The only exceptions are when a customer complaint proceeds to a civil claim, multiple subjects being named, or as noted above under FAQ 12. Details such as terminations for already-reported matters should be reported via the existing event.

17. What if I’m late filing a report?

File the report now but be sure to use the appropriate initiation date and include the reason for the late reporting.

18. What if the activity being reported involved an Approved Person, but the activity occurred at an affiliate (such as a bank or insurance company)?

Provide a clear summary of the misconduct, including whether the activity occurred with an affiliate or with the dealer and whether any member clients of the dealer were involved and if so, how.

19. What if I’m reporting activity for a former employee or I can’t find the employee? Should I create a new individual?

No. When choosing the “individual” subject, make sure you do not check the box for “Search employees only”. The name of the former employee should then appear when searched. If searching for non-employees does not help, please email ComSet@CIRO.ca.

20. What are the reporting timelines for Dealers to ComSet?

Customer complaints must be reported within 20 business days of receipt. All other matters must be reported within 5 business days of the occurrence of the event.

21. Where can I get any further help?

Log in to CIRO Services, choose ComSet from the left-hand menu and one of the applicable ComSet areas (Welcome, Search an Event, Reports). Once in the ComSet area, click on the “?” in the top right corner of the screen. This will take you to the comprehensive ComSet user guide which includes links to training videos and the applicable rules. For any questions not answered in the guide, please email ComSet@ciro.ca.