C-IIROC Client Focused Reforms


On Nov. 18, IIROC amended rules to align with client-focused reforms.


  • IIROC amended rules relating to account appropriateness, know-your-client (KYC), suitability, conflicts of interest, as well as relationship disclosure information (RDI).
  • Introduced new rules on product due diligence as well as know-your-product (KYP).
  • To make requirements uniform with CSA client focused reforms (CFR), see #65866.
  • Proposed product due diligence, KYP guidance for dealers, replaces Notice 09-0087.
  • Public Comment Amendments
  • Dealer must put person interest first for account appropriateness, C-IIROC Rule 3211.
  • Enhanced suitability determination in C-IIROC Rule 3402, incorporate CSA language.
  • Including requiring dealers to assess suitability based on an expanded list of factors.
  • Exemptions from core regulatory obligations of account appropriateness, suitability, KYC, product due diligence, and KYP for certain account and client types or services.
  • Also made updates to section references, language changes to reflect amendments.
  • Housekeeping Amendments
  • C-IIROC CFRs housekeeping amendments are duplicative of the CSA rule provisions.
  • Incorporated CSA CFR language in areas of training, conflicts of interest and KYC.
  • As well as relationship disclosure, pre-trade disclosure of changes, KYP, product due diligence, misleading communications, and general requirements to maintain records.
  • Consultation
  • Comments on the proposed amendments and new rules are due by Jan. 18, 2021.

Regulators C-IIROC
Entity Types B/D; IA; Inv Co
Reference RN 20-0238, 20-0239, 11/18/2020; Citation: *C-IIROC Rule* 3211, 3402;
Functions Compliance; Financial; Legal; Operations; Product; Reporting; Suitability; Trading
Countries Canada
Products Derivatives; Equity; Fixed Income; Fund Mgt; Securities
Regions Am
Rule Type Proposed
Rule Date 11/18/2020
Effective Date 1/18/2021
Rule Id 91023
Linked to Rule :65866
Reg. Last Update 11/18/2020
Report Section International

Last substantive update on 11/19/2020