Continuing Education Course Accreditation by IIROC

21-0196
Type: Administrative Notice> General
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Executive Summary

Following an internal review of the current process, the Investment Industry Regulatory Organization of Canada (IIROC) has decided to assume direct responsibility over the accreditation of Continuing Education (CE) courses for Dealer Members or external course providers who wish to submit them, as per IIROC Rule 2703 (4).

The Continuing Education Course Accreditation Process Centre (CECAP) is currently under agreement to provide IIROC with CE course accreditation services and will continue to do so for the duration of the current CE cycle. IIROC will assume direct responsibility over CE course accreditation as of January 1, 2022 and end its agreement with CECAP on December 31, 2021.

This Notice sets out the changes to be implemented regarding the accreditation process, including application submissions, fees and review criteria.  

Table of contents
  1. Background

IIROC Rules require Approved Persons to meet their CE obligations to enhance and further develop baseline licensing proficiencies.  Dealer Members or external course providers may offer Approved Persons CE courses. IIROC Rule 2703(4) specifically allows a Dealer Member or external course provider who wishes to accredit a CE course to use IIROC’s accreditation process.

CECAP is currently under agreement to provide IIROC with CE accreditation services.  CECAP has provided these services since 2004, which includes website administration, processing applications, evaluating courses and recommending CE credit hours for final IIROC staff approval. The Canadian Securities Institute (CSI) bought CECAP in 2006.

In Proficiency Assurance: The Next Phase in Proficiency Regulation,1 IIROC announced it would review its relationship with CECAP as part of a broader initiative to maintain a robust proficiency regime with high standards and effective regulation.  The review is now complete.

IIROC conducted an extensive review which supports the decision to bring the accreditation service in-house. We analyzed CE course accreditation practices across several regulated sectors, including insurance, law, real estate, and several regulated health professions.

We compared accreditation delivery models, course evaluation criteria, assessment procedures and fees to determine the best model for IIROC. We also reviewed related aspects of continuing education and course accreditation with the IIROC Proficiency Committee, La Chambre de la Sécurité Financière (CSF) in Quebec, FP Canada and The Financial Advisors Association of Canada (Advocis) in Ontario.

Our main finding is that regulators and professional standards bodies commonly perform continuing education course accreditation in-house using methods that suit their membership, CE program requirements and proficiency criteria.

IIROC is of the view that directly providing CE accreditation services will enhance service, quality control and transparency while offering a lower fee.

Going forward, IIROC will assume direct responsibility over CE course accreditation and end its agreement with CECAP on December 31, 2021.

  1. Current CE Rules

IIROC is not at this time proposing to change its CE Rules. Dealer Members or external course providers may provide CE courses for Approved Persons.  IIROC CE accreditation will also remain an option under Rule 2703(4). However, we remind Dealer Members that although they do not need to seek IIROC accreditation, our Rules require that they comply with IIROC CE program requirements and the Dealer Member administration criteria in Rule 2717.  

IIROC will continue to respond to specific inquiries about Dealer Member CE course administration, including accreditation, sent to [email protected].

Rule 2703(1)2 separately lays out substantive requirements for Compliance and Professional Development courses. Guidance on IIROC’s Continuing Education Program further describes examples of relevant types of course content we accept when reviewing accreditation applications.

  1. Summary of the Accreditation Process (Effective January 1, 2022)

Below is a brief summary of the application process and review. More detail is contained in the Application Form. A copy of the current Application Form is attached in Appendix A, and an up-to-date version will be maintained on our Forms page.

  1. Application process and fees

For IIROC to accredit a CE course, an applicant must download and submit the Application Form to [email protected].  A complete application includes the necessary information for IIROC to determine if a course is eligible for accreditation and the appropriate number of CE credit hours.

After receiving a completed application, and following receipt of payment, IIROC may contact an applicant for additional information and course content. We may deem an application abandoned if an applicant fails to provide the requested information within 20 business days. 

For the cycle starting January 1, 2022, IIROC will set a flat application fee of $300 per course for accreditation.3 The fee is calculated on a cost recovery basis and may be re-evaluated for future CE cycles. The fee is payable by credit card via our accreditation payment page.

We aim to conclude application reviews within 15 business days from the date we receive a completed application and payment.

  1. Application review

IIROC will review applications to determine if a course is eligible for accreditation, the appropriate number of CE credit hours, and to confirm the CE course type (i.e., compliance or professional development). We will use the information collected through the application form to make these determinations. We are of the view that the information collected will allow us to ensure an appropriate level of quality control, streamlining and transparency that is consistent with our high proficiency standards.

The application form requires applicants to provide descriptive information on the following six areas to facilitate our review:

  1. General objective(s) of the course

Applicants need to describe course content, which includes relevant information about the course’s objectives and provide a course outline or table of contents alongside a breakdown of each course element by percentage.

We deduct CE credit hours for irrelevant topics, promotional and proprietary content. Promotional and proprietary content include:

  • detailed descriptions of investment products
  • information readily available on an investment prospectus
  • portfolio positioning or composition
  • firm, team or product performance
  • promotion of proprietary tools, and
  • promotion of books or other educational materials.

Applicants need to list all promotional and proprietary content for us to assess the appropriate amount of CE credit hours, and what if (any) deductions need to be made. IIROC will provide written reasons for deductions and declined courses.

  1. Proficiency enhancement for CE participants

Applicants need to explain how a course will enhance and further develop a CE participant’s baseline licensing proficiencies. We include a drop-down list of topics to select for both Compliance and Professional Development courses where appropriate.

  1. Qualified instructional personnel

We are of the view that those responsible for course planning, development and delivery should have the training, credentials and knowledge that a reasonable person would find necessary to perform the activity competently.   Applicants need to list the individual qualifications of those involved in CE course planning, development and delivery.

  1. Instructional delivery methods

Applicants are asked to provide information on course duration and delivery methods in order for us to assess the correct number of CE credit hours to apply.  This includes listing all relevant educational materials, media and technological resources to be used in teaching the course. We include a drop-down list of delivery methods for applicants to select where appropriate.

IIROC will calculate CE credit by the quarter hour.4 For example, a course that runs for three-quarters of an hour (45 mins.) will typically earn three quarters (0.75) of a CE credit hour minus deductions. We make deductions in 0.25 CE credit hour increments for any content that fails to meet our CE requirements, such as irrelevant topics, promotional or proprietary content.

  1. Assessment strategies

Applicants need to provide information about a course’s assessment strategies. The strategy should reflect a course’s stated objectives, instructional methods and help us to assess total course duration. We provide a drop-down list of options for selection where appropriate.

Applicants will need to either list details about their assessment materials and methods or describe how they plan to ensure a CE participant has met the intended objectives.

  1. Control measures to ensure participation

To ensure that an applicant has appropriate control measures in place to track CE participation based on instructional strategies and assessment strategies used, applicants are asked to describe the control measures put in place to ensure CE participants are present and actively learning.         

  1. Other information

For auditing purposes, we may ask external course providers for further information up to three years after the end of the CE cycle. Rule 2717(1) (ii) specifically requires Dealer Members to keep all continuing education program records and course related materials for a minimum of seven years after the end of a CE cycle.

We will require applicants to notify IIROC of any material changes to an accredited course, by emailing  [email protected] within 20 business days of the change.

  1. Applications prior to January 1, 2022

As of November 1, 2021, those seeking IIROC accreditation for the upcoming cycle, including those accredited by CECAP in previous cycles, may submit the course(s) for review using the Application Form, and making payment via our accreditation payment page.  We will finalize the review and publish the list of accredited courses after January 1, 2022.

For specific questions on the application review prior to the launch of the new program, please contact [email protected]. 

  1. Applicable Rules

This Notice relates to IIROC Rule 2700 (CE Rule 2650). 

  1. Related documents 

  • Guidance on IIROC’s Continuing Education Program
  1. Appendices

Appendix A - IIROC Continuing Education Course Accreditation Application Form

  • 1. Notice 15-0215 (September 22, 2015)
  • 2. Rule 2703(1): The continuing education program consists of two parts: 
    a compliance course, which is training covering ethical issues, regulatory developments and rules governing investment dealer conduct, and 
    a professional development course, which is training that fosters learning and development in areas relevant to investment dealer business.
  • 3. Additional taxes will apply subject to the rate(s) set in the province of the applicant’s place of business.
  • 4. We will require a minimum CE course accreditation request for 0.5 CE credit hour and no course worth less than 0.5 CE credit hour after deductions will be approved.