Notice of Business Changes

General Information

Dealer Members are required to provide written notification to CIRO of certain business changes, as set out in the Mutual Fund Dealer Rules or the Investment Dealer and Partially Consolidated Rules, as applicable.

Dealer Members should only submit their business change request if they intend to implement the change upon obtaining CIRO approval, or shortly after.

Mutual Fund Dealer Members

Mutual Fund Dealer Rule 600 describes events that Mutual Fund Dealer Members are required to report to CIRO. Reportable events include, but are not limited to:

any change in the Member’s legal name or trade name(s)
any change in address or main telephone number of the Member
any change in the type of registration or licensing with the relevant securities commission
any change in the jurisdictions where the Member conducts dealer business
any change in the investment products traded or dealt in
any change in the Member’s directors, CEO, UDP, CCO CFO, or COO or individual performing the functional equivalent of any of those positions
any business, other than the sale of investment products, which the Member engages in or proposes to engage in

In addition to these reporting requirements, Mutual Fund Dealer Members are also required to report other types of events, which include but are not limited to:

entering into an introducing/carrying dealer arrangement
the Member changing its designated dealer level (e.g., changing from Level 2 to Level 3)

Investment Dealer Members

Section 2246 of the Investment Dealer and Partially Consolidated Rules (IDPC Rules) requires Investment Dealer Members to notify CIRO in writing before any material change to their business activities. Refer to Guidance Note GN-2200-21-001 for more information on the purpose of this notification requirement and what constitutes a “material change’ to a Dealer Member’s business activities.

Business Change Notification Process

Dealer Members seeking to implement a material change to business activities must provide CIRO with complete and accurate information regarding the proposed business change, with key elements finalized. This ensures an efficient and continuous review process.

The notification process for business changes is outlined below. For questions, please contact [email protected].

Prepare the Notice

1. Review the Notice of Material Business Change tool (PDF), including any supporting materials referenced therein.

CIRO has developed the Notice of Material Business Change tool (PDF) to assist Investment Dealer Members prepare a fulsome submission to CIRO of their proposed business change. To avoid delays in processing, complete all sections of the tool. Ensure any supporting materials are labelled with the corresponding section number of the Notice of Material Business Change.

Below are other tools and checklists designed to assist Investment Dealer Members to prepare supplementary materials to support their Notice of Material Business Change.

Policy Review Checklist (PDF) – This tool assists Investment Dealer Members assess the impact of the proposed business change to their policies and procedures (P&P) and organize how those P&P changes are included in the Member’s Notice of Material Business Change.

Financial and Operational Tools & Checklists: These tools assist Investment Dealer Members prepare information and materials to support business changes that pertain to the following:

Supplemental Documentation Checklist for Crypto Asset Trading Platforms (PDF) – This new resource outlines the additional materials that CIRO Dealers must submit when applying to add a Crypto Asset Trading Platform.

The Notice of Material Business Change is not applicable for Mutual Fund Dealer Members. Instead, Mutual Fund Dealer Members should provide a detailed written notice describing the business change and any relevant supporting materials.

Submit the Notice

2. Submit the Notice and supporting materials to CIRO.

Submit the required notice (e.g., the Notice of Material Business Change) and any supporting materials to [email protected]. Alternatively, Members may request a ShareFile link from [email protected]. The notice submitted by the Member must contain sufficient information and documentation for CIRO to commence a meaningful review of the proposed change. Incomplete submissions, or submissions with material deficiencies, will not be accepted for review.

Once CIRO staff have determined the submission to be substantially complete, CIRO will provide a written confirmation to the Member that the notice has been accepted for review.

3. Update the firm’s registration information with the securities regulatory authority in the applicable jurisdictions.

Depending on the type of business change, Members may be required to also update their firm registration information with the applicable securities regulatory authority of the Canadian Securities Administrators. Information on how to update the firm’s registration with the CSA can be found on the websites for each jurisdiction. Please refer to the Regulatory Links below.

While Your Notification is Under Review

4. Respond to follow-up information requests from CIRO staff during the review process.

The completeness of the Member’s notification and their responsiveness to CIRO staff inquiries directly affect the processing time for the proposed change. However, business changes involving complex models or requiring exemptive relief from securities rules will necessitate additional review time. Members should expect to work closely with CIRO staff during the review to clarify information and address potential issues, ensuring an efficient process.

CIRO staff will set deadlines for the Member to provide additional materials or responses, and Members are expected to submit substantially complete and accurate information within the specified timeframe to maintain progress. If a deadline cannot be met, Members may request an extension in writing. For material change to business activities applications, CIRO is committed to a 20-business day response timeline, provided the Member’s submission is thorough and accurate.

Note that during the review process, Members may also be requested to submit filings related to individual registrants through the National Registration Database (NRD) in accordance with NI 33-109.

Completion of CIRO’s Review

5. Wait for confirmation that CIRO’s review is complete.

Once CIRO staff have completed their review of the Member’s proposed business change, CIRO will inform the Member in writing that the review is complete and either: (a) confirm approval or non-objection to the proposed business change, or (b) direct that the business change not be completed if CIRO staff determine that the obligations of the Member to its clients cannot be satisfied or that the Member will not comply with CIRO’s By-laws and Rules as a result of the proposed business change.

Additional Resources

Regulatory Links

Quick Links

Notice of Material Business Change (PDF)