Independent Dealers Group

The Canadian Investment Regulatory Organization (CIRO) has significantly expanded the gatekeeper obligation through recent enforcement decisions in a way that departs from historical practice, creating uncertainty, fairness concerns, and increased risk for investment dealers. We argue that any change to the gatekeeper standard should be made transparently through formal rulemaking or policy development (not through enforcement) so the industry has clear, consistent, and workable guidance. Pre-budget consultation: Suggesting that the government create a more attractive investment environment by streamlining regulatory processes and reducing bureaucratic hurdles that often deter both domestic and foreign capital. Pre-budget consultation: Suggesting implementing a program that promotes entrepreneurship; Suggesting a Pro-Canada Investing program; Suggesting implementing a targeted foreign direct investment program. Pre-budget Consultation: Suggesting encouraging capital investment in early-stage “junior” companies listed on Canada’s two venture exchanges (TMX-V and CSE) by allowing capital gains on these investments to be tax-free; Suggesting implementing reforms to existing tax-assisted retirement savings programs; Suggesting a federal tax system and spending comprehensive and independent review. GST/HST on Trailer Commissions. CRA has reversed its longstanding position on GST/HST on Trailer Commissions (mutual funds). We believe the reversal does not take into account the negative impact on Investment Dealers, does not benefit CRA or investors, and should be reassessed.