Delivery of Documents During a Postal Strike or Lockout

A nationwide postal strike or lockout may occur as early as November 3, 2024. In the event of such postal strike or lockout, Dealer Members must take steps to ensure that document delivery requirements prescribed under CIRO Rules, and other applicable requirements continue to be met, irrespective of the manner in which such documents are delivered.

Dealer Members are encouraged to review how obligations to deliver documents can be satisfied electronically pursuant to National Policy 11-201 – Electronic Delivery of Documents (NP 11-201), and, as necessary, to consult with the various CSA member jurisdictions for any local requirements that might apply.

Members are reminded that they must comply with CIRO By-laws and Rules, securities legislation, and any other applicable laws and regulations that apply to Member activities, as set out under IDPC Rule 1406, and MFD Rule 1.1.2.

CIRO Recommendations

If there is a postal strike or lockout, we recommend Dealer Members take the following actions:

1. Advise your clients there could be a delay receiving documents that are sent to them by regular mail and discuss alternate arrangements with the client if they require the document urgently.
2. Provide your clients with the opportunity to receive trade confirmations and account statements by other means such as email1 or fax. For clients who do not have these services, where practical, consider courier delivery2 to clients directly or to branch offices for client pickup.
3. Remind your Approved Persons to confirm trades and communicate cash and margin calls by telephone. Provide your Approved Persons with suggestions for how clients can obtain documents, make payment or deliver securities.
4. Several documents are required to be delivered under the relevant securities legislation or CIRO Rules. Arrange alternate means for delivery of those documents.
5. Electronic delivery is the most efficient method of delivering documents to CIRO in the event of a postal strike or lockout; however, where practical you may use courier services instead of mail delivery. When sending information to CIRO, you must continue to meet applicable delivery requirements, including those relating to information privacy.

• 1Email includes an email to a client’s personal email address and emails delivered to a client through an electronic document delivery system, provided the practice complies with applicable securities regulations.
• 2Courier delivery includes private couriers, such as bike couriers and commercial couriers, such as FedEx, Purolator and UPS. Interoffice mail can also be considered a delivery option when sending documents to branches for client pick-up.