CRM2 may be one of the most important industry developments in decades, says the Investment Industry Association of Canada (IIAC) in a recent letter.
As well, the association says IIROC’s CRM2 reforms are a “consolidation of a good number of changes, each of which is significant.”
As a result, IIAC has formed a CRM2 working group and several related committees to help tackle and coordinate the implementation of reforms.
Its goal is to ensure client relationships aren’t strained as firms deal with CRM2 changes. This is crucial since the relationship model’s “multi-stage, multi-entity implementation requires extensive planning [and] development,” says IIAC, which finds firms already have to develop and test new systems and workflows.
So, they need to be protected from over-regulation throughout the process.
In its letter, IIAC mentions that the CSA and IIROC worked together to create the CRM2 initiative. It stresses that, “Although CRM2-related parts of National Instrument (NI) 31-103…are final, and [though] detailed analysis…of IIROC Rules [is] underway, dealer members’ CRM2 implementation may be impeded if there are further changes to CSA rules…or if a different understanding of requirements is presented by IIROC or CSA staff” in the future.
And, “given the tight timelines and extensive…issues facing dealer members in the CRM2 implementation [phase], it’s crucial for [those members] to have certainty immediately that CSA will [both] approve IIROC rules and exempt dealer members from…relevant portions of the CSA rules” related to NI 31-103 section 14 provisions.
Read: Get ready for CRM II
IIAC explains, “We know the CSA and IIROC are aware [that] the…pace of securities regulatory change that has taken place over the past five years, [along with] the implementations slated for at least the next three years, [has been] considerable.”
Since some dealer members have already exited the industry due to growing costs and demands, regulatory bodies need to provide realistic timelines and aid firms as they tackle CRM2 and related reforms.
Click here to read more about IIAC’s concerns and recommendations.