Association also highlights areas for improvement
TORONTO, Nov. 17, 2025 /CNW/ - SIMA has responded to the Canadian Investment Regulatory Organization's (CIRO) proposed guidance on Order Execution Only (OEO) account services. The submission highlights SIMA's overall support for CIRO's initiative to modernize and clarify OEO account regulation, while also identifying several critical areas for further refinement.
SIMA's recommendations focus on greater clarity on regulatory expectations, business model neutrality, enhanced investor empowerment, comprehensive conflict-of-interest management, and the importance of accessibility and inclusivity in decision-making tools.
"The proposed guidance represents a major step forward in supporting and fostering innovation in Canada," said Andy Mitchell, President and CEO of SIMA. "We welcome CIRO's commitment to principles-based regulation, but we urge further refinement to ensure business model neutrality, clarify regulatory expectations, and continue investor empowerment. Clearer terminology and ongoing flexibility will help firms thrive in a technology-driven environment and assist investors in achieving their goals."
Suggested improvements
While generally supportive of the proposal, SIMA urges CIRO to address these concerns:
- The phrase "specific investment decision" should be clarified and defined as "directly endorsing or recommending the purchase, sale, or holding of a particular security."
- The expanded definition of "recommendation" should not inadvertently restrict benign investor behavioral nudges or educational tools.
- Examples provided in the guidance should be illustrative, not prescriptive, to avoid constraining future innovation.
- The phrase "very limited range of products" needs a precise definition to avoid penalizing platforms unfairly.
- Examples provided in guidance should be illustrative, not prescriptive, to avoid constraining future innovation.
- Further clarity is needed regarding the role of delivery methods in communications, following the removal of the push/pull model.
- CIRO should harmonize terminology across the proposed guidance and the IDPC Rules, particularly terms such as "security," "class of security," and "issuer," to promote clarity and consistent interpretation for dealer members.
- The inclusion of specific securities within sample portfolios should be permitted provided that they don't endorse any specific product and there are appropriate disclosures confirming that sample portfolios do not, directly or indirectly, constitute recommendations.
- CIRO should allow pre-population of decision-making supports with objective client-provided data in order to enhance the client experience.
SIMA looks forward to continued constructive engagement with CIRO and industry stakeholders to shape a regulatory framework that protects and empowers investors, enables innovation, and supports a diverse range of dealer models.
About SIMA
The Securities and Investment Management Association empowers Canada's investment industry. The association is the leading voice for the securities and investment management industry, which oversees approximately $4 trillion in assets for over 20 million investors and the Canadian capital markets. Our members--including investment fund managers, investment and mutual fund dealers, capital markets participants, and professional service providers--are committed to creating a resilient, innovative investment sector that fuels long-term economic growth and creates opportunities for all Canadians.
SOURCE Securities and Investment Management Association
For more information: Christine Harminc, Director, Communications and Public Affairs, [email protected], 416-309-2313
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