What does CIRO look for in meeting documentation?

CIRO expects documentation that demonstrates a reasonable basis for each suitability determination, addressing five factors: client KYC information, KYP assessment, account impact, cost impact, and consideration of reasonable alternatives. These requirements are codified under the Client Focused Reforms in IDPC Rule 3402(1) and NI 31-103 s. 13.3(1).

Does CIRO require notes for every client meeting?

CIRO's rules are principles-based and directed at dealer firms, not individual advisors. There is no explicit rule mandating notes for every meeting. However, the obligation to demonstrate compliance through documentation creates a practical expectation that significant client interactions are documented. Case precedent (Re White, 2024 CIRO 67) established that contemporaneous meeting notes carry persuasive evidentiary weight.

How long must advisors keep meeting documentation records?

CIRO requires a minimum seven-year retention period under IDPC Rule 3800. The MFDA equivalent (Rule 5.6) imposes the same standard, as does NI 31-103 s. 11.6. Records must be stored in a manner that allows them to be produced upon request during a CIRO examination. Systems with audit trails or timestamps strengthen the evidentiary value of the records.

How quickly do meeting notes need to be completed?

CIRO does not prescribe a specific documentation timeline. No "same day" or "24-hour" rule exists. Case law establishes that notes taken during or immediately after meetings, stored in systems with audit trails, carry the most evidentiary weight. This is best practice drawn from enforcement precedent, not a binding timeframe.

What is the difference between a CIRO examination and an audit?

CIRO conducts "examinations," not "audits." An audit verifies financial statements; a CIRO examination assesses regulatory compliance. Three streams exist: Business Conduct Compliance (BCC), Financial and Operations Compliance (FinOps), and Trading Conduct Compliance (TCC). BCC examinations are most relevant to advisor documentation. ---

What is the difference between a CIRO examination and an audit?

CIRO conducts "examinations," not "audits." An audit verifies financial statements; a CIRO examination assesses regulatory compliance. Three streams exist: Business Conduct Compliance (BCC), Financial and Operations Compliance (FinOps), and Trading Conduct Compliance (TCC). BCC examinations are most relevant to advisor documentation. ---

CIRO Compliance Financial Advisors Meeting Documentation Canada

What CIRO Requires in Meeting Documentation (2026)

CIRO's five-factor suitability standard and Staff Notice 31-368 show what meeting documentation must demonstrate. The gap is smaller than you think.

Sandy

April 16, 2026

17 min read

TL;DR

CIRO requires meeting notes to demonstrate a reasonable basis for each suitability determination across five specific factors, codified in IDPC Rule 3402(1) and NI 31-103 s. 13.3(1). The standard was detailed through practical examples in Joint CSA/CIRO Staff Notice 31-368, published December 2025. The gap between current practice and compliance readiness is smaller than most advisors expect.

Sandy

Founder, Northern Catalyst | Developer, Meeting Notes Pro

Building tools for Canadian financial advisors

What CIRO Requires in Meeting Documentation (2026)

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