In Canada, CSA and CIRO just released findings from their Phase 2 sweep of 105 firms and the results are sobering

December 17, 2025

In Canada, CSA and CIRO just released findings from their Phase 2 sweep of 105 firms and the results are sobering.

Three years after Client Focused Reforms took effect, regulators found "basic, serious gaps" in how firms handle KYC, KYP, and suitability. Many firms required corrective action. Some cases warranted further regulatory action.

The Core KYP Issues:

·     Insufficient documentation of security assessments

·     Inadequate monitoring frequency (annual reviews= not enough)

·     Missing analysis of parties, conflicts, and counter parties

·     Lack of documented approval processes

·     Incomplete KYP for proprietary products and model portfolios

The Reality:

Regulators emphasized that firms "did not update their processes to fully reflect these new requirements." After years of FAQs and guidance, the transition period is ending.

The Solution Firms Need:

When managing due diligence across hundreds of securities and advisors, manual processes can't deliver the comprehensive, continuous documentation regulators now demand.

Our AI-powered investment due diligence platform provides:

·     Real-time monitoring of every security

·     Automated aggregation and analysis at scale

·     Documented research and audit trails

·     Consistent processes across all advisors

The CFRs aren't new anymore. Firms that haven't built scalable compliance infrastructure are running out of runway.

💡Ready to transform your investment due diligence process? Learn how Buckler IDD helps firms meet CFR requirements at scale at www.buckler.ai

December 17, 2025