Canadian Council of Insurance Regulators (“CCIR”) and the Canadian Insurance Services Regulatory Organization’s (“CISRO”) Proposed Consolidated Segregated Funds Guidance is meant to consolidate regulatory expectation and harmonize it with CIRO mutual fund dealer rules and related guidance.

The IIAC supports a principle-based approach to regulation that does not create unnecessarily burdensome expectations for insurers and intermediaries. To maintain that approach, we recommend that the CCIR/CISRO remove certain expectations as listed and described ici.