The Canadian Forum for Financial Markets (CFFiM) has submitted its review of Phase 6 of CIRO’s Consolidation Project.

The CFFiM welcomed with appreciation CIRO’s acceptance of multiple of the CFFiM’s earlier recommendations in prior phrases including:

• The withdrawal of the CIRO Board’s proposed power to expand CIRO’s jurisdiction over “investment products” as originally proposed.
• Narrowing the definition of “Executive”.
• Removing proposed jurisdiction over outsourcing arrangements that are unrelated to securities.
• Narrowing the definition of “serious misconduct”.
• Omitting ‘prospective clients’ from the definition of “complaint”.
• Removing the concept of “non-reportable complaint”.
• Removing the requirement to complete a “compliance review” as part of all internal investigations that are prompted by serious misconduct.

Cumulatively, CIRO’s acceptance of these recommendations has a positive, significant impact on defining CIRO’s scope and reducing unnecessary administration.

The CFFiM’s further review focussed on recommendations that provide as clear, comprehensive, and commercially reasonable ruleset for CIRO dealers , within the limitations of the current process. Generally, these recommendations focus on:

• Promoting innovation through a consistent and technology-neutral regulatory approach;
• Supporting advisory and order execution only channels;
• Ensuring that new proposed regulatory obligations have basis, remain appropriately within CIRO’s mandate and do not extend beyond its jurisdiction;
• Avoiding duplicative reporting;
• Avoiding unnecessary or excessive reporting requirements; and
• Promoting fair and efficient complaint handling procedures to maximize the benefits of both internal and external dispute resolution options for clients.

Detailed comments are here with suggested amendments included at Schedule “A”.