ARTICLE
7 April 2026

Dropping The Double-double: CIRO Proposes To Retire Dual Registration

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Borden Ladner Gervais LLP

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On February 12, the Canadian Investment Regulatory Organization (CIRO) proposed to end the dual registration model, enabling investment dealers to operate a mutual fund division without separate...
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On February 12, the Canadian Investment Regulatory Organization (CIRO) proposed to end the dual registration model, enabling investment dealers to operate a mutual fund division without separate registration as a Mutual Fund Dealer. The change is anticipated to facilitate advisor mobility and give firms the ability to operate both types of business without requiring mutual fund only advisors to upgrade their proficiencies to those of an advisor at an Investment Dealer Member.

To accomplish this, CIRO proposes to repeal the proficiency upgrade requirement for mutual fund-only advisors who work at an Investment Dealer Member and codify exemptive relief conditions under which existing dual-registered firms operate. Currently, a Registered or Investment Representative dealing only in mutual funds who is employed by an Investment Dealer only is required to upgrade to meet the proficiency requirements applicable to either a Registered or Investment Representative within 270 days of approval.

Comments on the proposal are due on June 12, 2026, and should be considered together with the Proposed CIRO Rules (the consolidated investment dealer and mutual fund dealer rules) for a complete picture of the potential impact on firms and their advisors.

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