FAIR Canada’s submission on Phase 6 of CIRO’s Consolidated Rulebook Project makes a broader point about what the rule consolidation should deliver for investors. A shift toward more principles-based regulation should not be treated as a move to lighter-touch regulation. If CIRO’s rules become broader and more flexible, CIRO’s operations must become stronger, more transparent, and more accountable. That means more detailed guidance so dealers, representatives, investors, and the public can understand how broad principles will be interpreted and applied; more effective compliance monitoring to assess whether firms are meeting the spirit and purpose of the rules; and rigorous enforcement when firms fall short of their investor protection obligations. Transparency is also essential across all three of these areas. A principles-based rulebook can only strengthen investor protection if it is supported by clear expectations, active oversight, credible enforcement, and meaningful public reporting.
FAIR’s submission also highlights the need for a modern registration regime that is built around the investor’s experience. The current framework still reflects historical business models more than the investor’s perspective. Multiple registrations within the same firm, and limited licensing within full-service firms, can create confusion for investors who reasonably expect that anyone presented to them as an advisor has met minimum standards to provide financial advice. Most investors do not know the difference between an investment representative, a registered representative, a mutual fund dealing representative, or an exempt market dealing representative, and they should not be expected to research the boundaries of each category. CIRO’s vision for the future should be a modern, investor-centric registration regime and not one constrained by historical product-based categories.