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Significant implementation delays announced for client focused reforms and IIROC plain language rules

In a series of announcements this week, the CSA, IIROC and the MFDA delayed the implementation of certain significant regulatory initiatives, primarily as a result of the COVID-19 situation. Specifically, the implementation of certain Client Focused Reforms (CFRs) and IIROC’s Plain Language Rules (PLRs) will be delayed as follows:

  • CFRs – conflicts of interest provisions: the effective date by which registrants will have to comply with the conflicts of interest provisions in the CFRs is postponed by six months, until June 30, 2021.
  • CFRs – relationship disclosure information (RDI): the implementation of the RDI provisions of the CFRs is delayed by a year, until December 31, 2021.
  • PLRs: the implementation of IIROC’s PLRs is delayed by a year and a half, until December 31, 2021.

The CFRs are a significant regulatory initiative based on the concept that in the client-registrant relationship, the interests of the client come first.

IIROC’s PLRs will introduce both material and non-material changes to the IIROC dealer member rules, including changes to registration requirements, such as the re-introduction of the categories of Associate Portfolio Managers and Portfolio Managers, and changes to proficiency requirements.

For more details regarding the CFRs and the PLRs, please see our previous blogs HERE and HERE.

client focused reforms relationship disclosure information Plain Language Rules



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