CIRO proposes 60-day complaint responses for Canadian investment dealers

The Canadian Investment Regulatory Organization proposed on 29 October that investment dealers and mutual fund dealers move to a national 60-day standard for responding to investor complaints. Its plan allows another 30 days for complex cases or delays beyond a dealer’s control. The changes are open for consultation and have not taken effect.[2]

Québec already operates a shorter timetable. The AMF’s framework, effective since 1 July 2025, requires a written final response within 60 days, with exceptional circumstances allowing up to 90. Where more time is needed, the firm must explain the delay and give a response date in writing within the initial 60 days.[3]

Elsewhere in Canada, CIRO’s current baseline is 90 days. The consultation would amend the existing investment-dealer and mutual-fund-dealer rules and carry the change into the planned consolidated rulebook.[1]

The extension would depend on the investigation

The proposal also retains room for rare investigations requiring more than 90 days because of extensive fact-finding or complex legal analysis. It does not add an obligation to report service complaints to CIRO.[1]

For a broker, the practical work would begin when a complaint arrives: identify the records needed, allocate an investigator and decide whether there is a specific reason for extra time. A shorter standard puts more weight on that initial assessment. Merely moving an unchanged queue forward by a month would leave less time to collect missing evidence and explain the decision.

Dealers consulted by CIRO favoured retaining 90 days, citing investigation quality, staffing and training. Investor advocates supported a shorter period. Those competing concerns make the extension criteria consequential: they determine how much of the proposed acceleration would reach clients in practice.[1]

A dealer’s answer and external redress have separate clocks

Under OBSI’s current process, an investor can approach the ombudsman after an unsatisfactory final response from a participating investment firm, or when the applicable response period expires. That period is generally 90 days, with the Québec 60-day standard and exceptional extension. A client has 180 days after the firm’s final response to bring a complaint to OBSI, which then assesses whether it can investigate.[4]

A faster final response can therefore give a client an earlier decision to challenge, but it does not itself determine compensation or finish an ombudsman investigation. Firms would need to keep the promised response date and the explanation of external options consistent, so a client can understand both what the dealer has decided and what remains open.

Comments are due by 27 January 2027. CIRO must consider responses and the subsequent regulatory approval process before implementation; the consultation provides no start date for a new national standard.[1]

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