On March 24th, 2021, the Board of Directors (the Board) of the Investment Industry Regulatory Organization of Canada (IIROC) approved the non-material amendments to Form 1 for use in, and consistency, with the terms and drafting protocol used in the IIROC Rules1 (the Amendments).
Form 1 is a special purpose report prescribed by IIROC for reporting a Dealer Member’s financial statements and regulatory capital position. Dealer Members must submit to IIROC a subset of Form 1 statements and schedules on a monthly basis and a complete audited Form 1 on an annually basis.
In 2018, we started a project to update Form 1 because this financial reporting document was in need of modernization. We identified the need to revise the language and structure of Form 1 to make it more clear, concise and organized. In 2019, we published two notices of approval / implementation2 regarding material and non-material changes to Form 1.
Summary of the Amendments
Since then, we have identified that further Form 1 amendments are required to ensure it remains current and consistent with the IIROC Rules.
The Amendments include:
- stylistic changes such as italicizing defined terms, re-formatting, re-organization and renumbering of notes,
- spelling, grammar and other related corrections,
- changes of an editorial nature such as the standardization of terminology, and
- re-drafting of sections to further conform with, or clarify, the existing IIROC requirements.
Attached as Appendix A is the table of concordance that tracks the amendments to Form 1 and provides a detailed description of each change.
Previously implemented amendments
The Amendments also include the addition of approved amendments that were implemented following the last publication of the 2019 revised Form 1. These amendments have been re-formatted where applicable to italicize defined terms and align with plain language conventions. These amendments include:
- the amendments to notes and instructions to Schedules 1 and 7 of Form 1 regarding agency tri-party arrangements3 ,
- the housekeeping amendments to Form 1 to adopt IFRS reporting requirements for leases4 , and
- the amendments to IIROC Dealer Member Rule 1200.3 and notes to Statement D of Form 1 regarding free credit cash segregated in trust for clients5 .
Implementation of the debt concentration project
Amendments relating to the securities concentration test and designated rating organizations will be implemented on September 1st, 2022, after the IIROC Rules become effective. We have re-drafted these Form 1 changes to conform with plain language writing conventions and included them in this package because a plain language conforming version was not included previously in IIROC Rules Notice 21-0028. To indicate the later implementation date of these amendments, we have placed them in grey boxes and indicated their later implementation date.
Classification of the Amendments
We have classified the Amendments as “housekeeping” because they:
- do not represent a material change to IIROC requirements,
- reflect stylistic changes and formatting changes,
- correct spelling and punctuation,
- make necessary changes of an editorial nature such as standardization of terminology, and
- are reasonably necessary to ensure Form 1 conforms with the IIROC Rules.
The Amendments will be effective on December 31, 2021, unless otherwise indicated in Appendices B and C.
Appendix A – Table of concordance
Appendix B – Blackline comparison of the Amendments to amended Form 1 in Notice 19-0180
Appendix C – Clean copy
- 2IIROC Rules Notices 19-0146 and 19-0180 – Both sets of amendments have the same implementation schedule as the IIROC Rules
- 3IIROC Rules Notice 20-0179 – Amendments to Notes and Instructions to Schedules 1 and 7 of Form 1 regarding agency tri-party arrangements
- 4IIROC Rules Notice 19-0036 – Housekeeping amendments to Form 1 to adopt IFRS reporting requirements for leases
- 5IIROC Rules Notice 19-0212– Amendments to IIROC Dealer Member Rule 1200.3 and Notes to Statement D of Form 1 regarding free credit cash segregated in trust for clients