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Christine Harminc
Conseillère principale, Communications et Affaires publiques

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IFIC makes submission on phase 2 of CIRO’s rule-consolidation project

March 11, 2024 (Toronto) – The Investment Funds Institute of Canada (IFIC) has made a submission to the Canadian Investment Regulatory Organization (CIRO) on phase 2 of its rule-consolidation project. When completed, the project will merge the two sets of rules that currently apply to investment dealers and mutual fund dealers into one set of rules, which will be known as the CIRO Dealer and Consolidated Rules.

“IFIC supports CIRO and this project,” said Andy Mitchell, IFIC’s President and CEO. “While CIRO is rolling out the project consultations in a suitably phased manner, we believe it is critical that the entire project come into force at the same time after a sufficient implementation period to avoid duplication of costs and effort and to reduce implementation risk.”

In our phase 2 submission, we reiterate the principles set out in our phase 1 submission, dated December 19, 2023, to help our members analyze the proposals in each phase of the project.

We recommend a sufficient implementation period for our members to make required IT changes and any necessary changes to policies and procedures, training and operational matters.  We also suggest ways to improve the efficiency of the consultation process for the remaining project phases. In particular, we urge CIRO to provide a minimum of 90 days for comments for subsequent, increasingly complicated phases of the rule-consolidation project.

IFIC is concerned that moving too quickly with either consultations or implementation could put the project at risk, which would be counter-productive to achieving the regulatory objectives and would undermine the confidence of dealers, investors and other stakeholders in securities regulation.

Our submission includes comments on three elements of the Phase 2 consultation: best-execution obligations; debt market trading and settlement practice obligations, and; transaction reporting for debt securities.

About IFIC

The Investment Funds Institute of Canada is the voice of Canada’s investment funds industry. IFIC brings together approximately 150 organizations, including fund managers, dealers, professional and back-office service providers, to strengthen the integrity of the investment funds industry, foster public confidence in investment funds, and enable investors to achieve good outcomes. By connecting savers to Canada’s economy, our industry contributes significantly to Canadian economic growth and job creation.

For more information, please contact:

Christine Harminc
Senior Manager, Communications and Public Affairs