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ARTICLE · 19 DECEMBER 2025

Under The Bright Lights: CSA & CIRO Illuminate Enhanced Expectations In Phase 2 Client-focused Reform Sweep

Borden Ladner Gervais LLP
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On Dec. 10, 2025, the Canadian Securities Administrators (CSA) and Canadian Investment Regulatory Organization (CIRO) published their much-anticipated findings from recent regulatory compliance sweeps of 105 registered...

CanadaCorporate/Commercial Law
Jonathan Doll
Jonathan Doll
Jason Brooks
Jason Brooks
Jean-Philippe Gagnon
Jean-Philippe Gagnon
Matthew Williams
Matthew Williams
Melissa Ghislanzoni
Melissa Ghislanzoni
Kimberly Poster
Kimberly Poster
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Unveiled at last

On Dec. 10, 2025, the Canadian Securities Administrators (CSA) and Canadian Investment Regulatory Organization (CIRO) published their much-anticipated findings from recent regulatory compliance sweeps of 105 registered firms in Staff Notice 31-368 Client Focused Reforms: Review of Registrants' Know Your Client, Know Your Product and Suitability Determination Practices and Additional Guidance (the Report).

Casting a spotlight on compliance programs

The Report summarizes findings and provides guidance arising from the regulators' reviews focused on assessing compliance with the Know Your Client (KYC), Know Your Product (KYP), and suitability determination requirements implemented as part of the so-called Client Focused Reforms, or CFRs. These were fundamental changes to registrant conduct requirements, implemented in two phases in 2021, through amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant

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