Client Focused Reforms - Do you have implementation questions?

Our role in supporting the implementation of the Client Focused Reforms

The Canadian Securities Administrators (CSA) as well as the Investment Industry Regulatory Organization of Canada (IIROC ) and the Mutual Fund Dealers Association of Canada (MFDA and together with IIROC, the SROs) have established the CFRs Implementation Committee (the Committee) to consider operational challenges industry stakeholders are facing and how to respond to them to ensure implementation per the phased transition periods, including in due course communication with industry at large.

We have compiled a list of questions received by the Committee to date and have set out our responses to provide guidance to registrants (see Frequently Asked Questions).

Your role

Industry stakeholders are invited to provide the Committee with their feedback regarding operational challenges they are facing implementing the Client Focused Reforms (CFRs). Stakeholders including law firms, consultants and other stakeholders that provide services to industry, are encouraged to complete the form on this website.

Click here to access form

Prior to submitting your feedback, you should refer to the summary of previous comments received during the CFR consultation period, which provides the policy decisions the CSA considered when finalizing the CFRs [see Annex B to the CSA Notice of Amendment].

Key things to keep in mind

All comments will be carefully considered. The CSA cannot provide a response to each submission received nor can we provide legal advice. Our goal is to provide, at a later date, additional guidance about operational issues shared by industry stakeholders.

The CSA would also like to remind registrants that even though the implementation has been delayed, registrants are encouraged to consider the reforms with every interaction they now have with their clients.

Thank you, in advance, for your submission.

CFR implementation background and key dates

The CSA recognizes the significant work many registrants need to undertake to implement the CFRs. In response to the unique challenges associated with the COVID-19 pandemic, the CSA granted relief to postpone the effective date by which registrants will have to comply with the conflicts of interest CFRs by six months to June 30, 2021. The CSA has been working with industry stakeholders through the Committee to gather feedback from industry on implementing the CFRs. Through the Committee, industry stakeholders informed the CSA of operational challenges associated with implementing the relationship disclosure (RDI) provisions of the CFRs. Accordingly, the CSA decided to also grant relief to extend the time which registrants will have to comply with the RDI CFRs. The implementation of the RDI CFRs will be postponed until December 31, 2021, so that they will come into effect at the same time as all remaining CFRs. For more details, please see CSA Notice 31-357 Blanket Orders/Class Orders in respect of Certain Client Focused Reforms Provisions of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations.

The SROs will harmonize their implementation timelines for conforming changes to their member rules, policies and guidance with the timeline adopted by the CSA.

No grandfathering provisions have been adopted by the CSA which means that all registrants will have to comply with the conflicts of interest CFRs by June 30, 2021 and with all CFRs by December 31, 2021.

Do you need technical support to complete your submission?

If you have a technical issue when completing your submission, please contact CSA Secretariat.

Where to find a copy of the CFRs?

The CSA first published the CFRs on October 3, 2019, making significant amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and Companion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations.

For further reference, the amendments are available on websites of CSA jurisdictions.