Becoming a Dual-Registered Firm

General Information

Firms that become registered as both an investment dealer and a mutual fund dealer will be eligible to conduct both investment dealer business and mutual fund dealer business within the same legal entity without having to upgrade the proficiencies of their mutual funds only licensed advisors. These firms are known as dual-registered firms.

Firms that wish to apply for membership as a dual-registered firm should refer to Becoming a Dealer Member. The information below is for existing Members that wish to become dual-registered.

Dual-Registration Process for Existing Members

The process for existing Members to become dual-registered is outlined below. If you have questions or need further information, please contact [email protected].

    Prepare the Application

    1. Review the Dual-Registration Questionnaire for Existing Members (PDF) and the Dual-Registration Documentation Checklist (PDF) for information on the materials that Members must prepare. 

    Applications to become dual-registered must undergo review by CIRO staff. The Dual-Registration Questionnaire (PDF) collects the information needed to assess the Member’s dual-registration proposal. The Documentation Checklist (PDF) sets out the additional materials, forms and supporting documents that must be included with the application.

    Reviewing the above materials ahead of time will help the Member assess whether it is ready to begin the dual-registration process.

    2. Contact CIRO’s Membership Intake team at [email protected] to book an introductory meeting.

    During the introductory meeting, CIRO staff will guide the firm through the application process, discuss relevant timelines, and identify key areas of the firm’s dual-registered proposal that will be assessed during the review.

    Submit the Application

    3. Submit a fully completed Dual-Registration Questionnaire (PDF) and the required supporting materials to CIRO.

    Once the Member is ready to apply for dual-registration, contact [email protected] to receive a ShareFile link and instructions for uploading the application package. Incomplete applications or applications with material deficiencies will not be accepted for review.

    Applicants can avoid unnecessary delays in the review and processing of their dual-registration application by:

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

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

    Becoming dual-registered is a two-pronged process. The Member must:

    • apply to become a dual-registered firm with CIRO; and
    • update its registration (e.g., add mutual fund dealer registration or investment dealer registration) with the applicable securities regulatory authority of the Canadian Securities Administrators (CSA), in each jurisdiction that the Member operates.

    Information on how to apply for dual-registration with the CSA can be found on the websites for each jurisdiction. Please refer to the Regulatory Links below.

    While Your Application is Under Review

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

    Members should expect to work closely with CIRO staff during the review process to clarify information and resolve potential issues.

    The completeness of the Member’s dual-registration application and their responsiveness to information requests from CIRO staff will impact the time it will take to process the application. Dual-registration applications that involve complex business models and those that require exemptive relief from securities rules will require additional time for CIRO review and approval.

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

    Application Approval

    6. Wait for CIRO confirmation of dual-registration approval.

    Once CIRO staff are satisfied that the Member’s dual-registration proposal meets applicable regulatory requirements, and the required CSA approvals are obtained, CIRO will provide the Member with written confirmation that the review is complete and issue an approval or non-objection letter to the Member.

    Note that any exemptive relief associated with a dual-registration application requires approval from CIRO’s Board of Directors.

    Regulatory Links

    Quick Links