Earlier this month, the Canadian Investment Regulatory Organization (CIRO) released its summary of rule exemptions granted by CIRO in 2023. Some common exemptions granted included:
- exemptions from UMIR provisions granted by CIRO staff from the rules relating to trading off-marketplace during a regulatory halt or a statutory hold period;
- exemptions granted by the CIRO board relating to dual registration to allow the operation of an investment dealer and mutual fund dealer within a single legal entity;
- exemptive relief pertaining to trading in crypto assets, relating to the requisite financial bond insurance and acceptable securities locations;
- relief regarding account opening requirements in relation to bulk account movements; and
- exemptions to allow certain approved persons to use corporate officer titles when interacting with clients.
With respect to proficiency and continuing education requirements granted by CIRO staff, it was noted that most applications related to the following courses:
- Canadian Securities Course;
- Partners, Directors and Senior Officers Course;
- Wealth Management Essentials; and
- 90-Day Training Program.
Usually, the applicants were required to demonstrate that their industry experience and education with respect to the first three listed courses were an acceptable alternative. The applications with respect to the 90-Day Training Program were mostly filed in connection with a transfer of individuals from a mutual fund dealer to a related investment dealer that was still providing the requisite training.
It is helpful to be familiar with the conditions imposed by CIRO in any particular exemptive relief granted, to assist in future if relief from the same rules is sought.
November 29, 2024