IIROC Proposes Minor Contravention Program And Early Resolution Offers

New disciplinary programs would seek to resolve cases efficiently without more formal disciplinary proceedings

• On April 25, 2019, the Investment Industry Regulatory Organization of Canada (IIROC) proposed the adoption of a Minor Contravention Program (MCP) and Early Resolution Offers.
• These new forms of disciplinary action would seek to address regulatory contraventions by encouraging early resolution of cases and avoid formal disciplinary proceedings.
• IIROC is accepting comments on the proposals until July 24, 2019.

Minor Contravention Program

Under the current disciplinary process, IIROC Staff have various options available to them following to the completion of an investigation into regulatory contraventions. Specifically, Staff may (i) take no action; (ii) issue a Cautionary Letter; or (iii) initiate formal enforcement proceedings. The MCP would target cases that require a more serious regulatory response than a Cautionary Letter but that don’t