The Canadian Investment Regulatory Organization (CIRO) has released a consultation paper that should be reviewed by every dealer member of the self-regulatory organization. CIRO’s proposed new proficiency model represents a significant change from current requirements and moves away from requiring exams tied to courses toward an assessment model with specific mandatory continuing education and training elements. The model is currently only focused on individuals at investment dealers.

The proposed new model would not include any mandatory courses but would require all prospective approved persons to write a general industry exam based on competencies common across all CIRO registration categories. Once the general exam is completed, an individual registrant would require sponsorship from a dealer prior to being permitted to write the additional exams, which will be specific for each approved person category (based on the proposed competency profiles which we have written about most recently here). It is proposed that there will be nine approved person exams available, details of which are found in the consultation paper. After approval for registration is granted, individuals would be required to take a mandatory professional conduct training course within 30 days of approval. In general, CIRO intends to take a larger role in program and exam design than in the past.

It is also proposed that on an annual basis, individuals would be required to engage in 1-3 hours of CE training on key regulatory topics set out by CIRO, as part of the current mandated applicable CE requirements.

Of interest to industry will also be the proposed new baseline education requirements for registered representatives to include a (as yet undefined) relevant diploma, degree, or two years of relevant experience in the financial industry. The consultation paper also notes that CIRO is of the view that each Executive at the dealer, including the UDP, should have the same experience requirements applicable to Supervisors in addition to the existing general experience requirements set out in the rules.

Among other next steps, CIRO plans to publish amendments to its proficiency rules by the fall of 2024.

Please look out for a future bulletin from AUM and our friends at BLG LLP with additional information and analysis. In the meanwhile, if you have any questions or wish to comment on the proposal, please reach out to us in advance of the comment deadline of September 20, 2023.

July 31, 2023