SIMA backs CIRO’s advisor incorporation model but flags team ownership risk
Under the proposal, dealer members would not be required to make the new incorporated advisor arrangement available to their client-facing approved persons – a flexibility SIMA explicitly supports, alongside the ability for approved persons to continue providing other financial services such as insurance and financial planning, given that many hold multiple licences.
“We appreciate the substantial work CIRO put into this important project, given the many complexities involved,” said Andy Mitchell, President and CEO of SIMA, in the association’s November 6, 2026 submission. “We also welcomed CIRO’s longer-than-usual consultation period, which allowed members to consider the framework more thoroughly. We support the model with a few key recommendations.”
Team model at risk
The association’s most pointed criticism targets the ownership restrictions in the current proposal. As drafted, only an approved person and related persons would be permitted as shareholders of an IAP corporation. SIMA is recommending that CIRO allow multiple owners – a change it says is necessary to protect team-based business models that are already well-established across the industry.
The association argues that team structures deliver better client outcomes, enabling continuity of service and smoother succession planning. Restricting ownership to a single approved person and their related parties would, in SIMA’s view, significantly disrupt existing operations and could ultimately harm investors who rely on those teams for comprehensive, multi-disciplinary advice.
SIMA also called for teams to be permitted to operate across disciplines, allowing advisors within a shared structure to offer a range of services to clients – a reflection of how modern practices are increasingly built around integrated wealth management rather than single-advisor models.
