At a regulators’ panel held in Montreal on May 8, 2025, industry leaders discussed the delegation of certain powers from the Autorité des marchés financiers (AMF) to the Canadian Investment Regulatory Organization (CIRO). 

The event was part of the 2025 Quebec investment conference, hosted by Securities and Investment Management Association (SIMA), formerly known as the Investment Funds Institute of Canada (IFIC). The panel provided an opportunity to review recent transfers of authority to CIRO. 

Since April 1, several members of the Canadian Securities Administrators (CSA) have entrusted CIRO with the registration of mutual fund dealers. These include regulators from Alberta, Ontario, New Brunswick, Nova Scotia, Prince Edward Island, Newfoundland and Labrador, Nunavut, the Northwest Territories, and Yukon. 

In Ontario, the Financial Services Regulatory Authority of Ontario (FSRA) has delegated to CIRO the registration of mutual fund dealers, investment dealers, and futures commission merchants. 

A joint CSA press release from April 1 noted that the British Columbia Securities Commission, the Financial and Consumer Affairs Authority of Saskatchewan, and the Manitoba Securities Commission “will follow suit in due course.” 

The AMF had already transferred certain responsibilities to CIRO in October 2023, including registration of mutual fund dealer representatives and compliance inspections for mutual fund dealers operating in Quebec. 

Quebec delegation: July 1 

The AMF is now expected to delegate additional powers to CIRO effective July 1, including the registration of mutual fund dealers, investment dealers, and derivatives dealers. CIRO will also oversee the registration of individuals working for these firms, including mutual fund representatives. 

“This means your initial registration applications and any other registration requests for individuals and firms in the mutual fund sector will now go through CIRO’s Montreal office,” said Pascale Toupin, Director of Intermediary Supervision at the AMF. 

Toupin clarified, however, that portfolio managers and investment fund managers will remain under AMF jurisdiction. In cases where a firm operates in both a CIRO-delegated category and a non-delegated one, the AMF will continue to collaborate with CIRO. 

Exemptive relief will also remain under the AMF’s authority, she added. 

CIRO expands its Quebec team 

In preparation for its new responsibilities in Quebec, CIRO’s Montreal office has more than doubled its staff, adding six new team members to bring the total to 13. “We’re adding a six-person team dedicated solely to the registration of mutual fund dealing representatives,” said Alexandre Bardoux, CIRO’s Regional Director of Member Regulation for Quebec and Atlantic Canada. 

Since April 1, CIRO’s Montreal office has also been handling individual registrations for the Atlantic provinces. “That covers four provinces, and since implementation, we’ve already had nearly 200 applicants,” Bardoux revealed. “We are confident we’ll be ready to implement the delegation efficiently.” 

Toupin noted that the AMF plays an active role in the CSA’s working group on harmonizing registration processes. “The goal is to create a single window and standardized procedures for all firms,” she said. 

The AMF’s involvement ensures that mutual fund distribution regulation continues to reflect Quebec’s unique regulatory framework, especially during the transition period. “For instance, even with the delegation of registration, dealers must still comply with National Instrument 31-103,” Toupin explained, referring to the regulation governing registration requirements and ongoing obligations across Canada, except in Newfoundland and Labrador and Nunavut. 

Reducing the burden for dealers 

During the panel, Maxime Gauthier, President and Chief Compliance Officer of Mérici Financial Services, asked about the timeline for the transition. Toupin confirmed that the AMF plans to implement the delegation of registration powers as scheduled on July 1. 

Gauthier also inquired about a recent exemptive decision related to the delegation of financial oversight from the AMF to CIRO. This decision, labeled 2025-pdg-0025 and issued on April 17, allows certain mutual fund dealers to avoid duplicative financial reporting to both regulators. 

Toupin explained that the exemption aims to alleviate regulatory burden by allowing mutual fund dealers registered exclusively in Quebec to submit their financial information solely to CIRO. “Without this exemption, firms would have been required to file with both regulators, which we consider an unnecessary burden,” she said. “This approach maintains investor protection, as the review and financial analysis are still conducted by CIRO’s Montreal office.” The exemption took effect on April 17, with all affected firms receiving a notification email. 

According to the AMF’s bulletin published the same day, the decision is designed to eliminate redundancies while safeguarding investor interests. Toupin emphasized that the exemption applies to activities such as financial reviews and analysis, now fully handled by CIRO in Montreal. 

Marie-Lyne Côté, Senior Director of Member Regulation at CIRO, elaborated on the practical implications of the exemption. “Audited financial statements, working capital calculations, and interim reporting will be submitted to CIRO,” she said. 

Firms must adhere to the reporting timelines set out in NI 31-103. For example, if a firm’s working capital falls below the required threshold, it must notify CIRO immediately. “We handle the follow-ups with firms, always in collaboration with the AMF,” Côté added. The same process applies to subordination agreements, whether for new arrangements or repayment of subordinated loans, as well as changes to external auditors. 

Côté specified that the exemption applies solely to firms registered as mutual fund dealers. Firms holding other categories of registration, such as investment fund managers or exempt market dealers, will still need to submit relevant information to both regulators.