The Canadian Securities Administrators and the Canadian Investment Regulatory Organization have published joint findings and additional guidance from a second phase of Client Focused Reforms reviews, assessing registrants’ compliance with enhanced know your client, know your product and suitability determination requirements across 105 firms. Joint CSA/CIRO Staff Notice 31-368 sets out notable observations from the sweep and provides guidance intended to help registrants implement efficient, tailored processes that better align with the Client Focused Reforms. While the review found many firms had updated processes and some invested significant resources, it also identified firms that had not fully updated their practices to reflect the new requirements, with those firms required to take action to address the compliance issues identified. The firms reviewed included investment fund managers, portfolio managers (including restricted portfolio managers), exempt market dealers, investment dealers and mutual fund dealers. The publication builds on the earlier conflicts of interest review and related guidance issued in August 2023 in Joint CSA/CIRO Staff Notice 31-363.
Canadian Investment Regulatory Organization 2025-12-10
Canadian Investment Regulatory Organization and Canadian Securities Administrators publish Phase 2 Client Focused Reforms sweep findings and guidance on KYC KYP and suitability
The Canadian Securities Administrators and the Canadian Investment Regulatory Organization released findings from the second phase of Client Focused Reforms reviews, evaluating compliance with know your client, know your product, and suitability requirements across 105 firms. Joint CSA/CIRO Staff Notice 31-368 highlights observations and offers guidance to improve registrants' processes. While many firms updated practices, some have yet to fully comply, necessitating corrective actions.