Insights You Can Use, Advocacy You Can Trust

INVESTOR RIGHTS MONITOR

Insights You Can Use, Advocacy You Can Trust.

January 2026

As we welcome 2026, I extend my warmest wishes to you and your loved ones for a happy, healthy, and prosperous new year.

January is a time for reflection and renewal. I want to thank our donors and supporters – your commitment enables FAIR Canada to remain an independent and trusted voice for investors nationwide. We are taking important steps to strengthen our organization and expand our influence, ensuring we can deepen our impact in the year ahead.

This month, we are proud to release our 2024 –2025 Annual Report, highlighting progress in key areas, including:

Improving the process for resolving investor complaints
Strengthening compensation and redress tools for harmed investors
Improving investor disclosure and enhancing shareholder engagement
Providing better tools and protections for DIY investors
Identifying and addressing emerging risks across the financial system

I encourage you to explore the report to learn more about our advocacy efforts and the impact we’ve achieved to date.

Looking ahead, 2026 promises to be another pivotal year for investor advocacy. Some of our advocacy will focus on:

Harmonized and enhanced complaint handling requirements for all securities registrants across Canada
Provincial legislation to establish the CSA’s binding framework for OBSI
Greater regulatory focus on Order-Execution-Only (OEO) firms given their increased use by retail investors and concerns with gamification, crypto investing, and finfluencers
Improving the account transfer process for the benefit of investors
Establishing appropriate investor protections where regulators propose to expand retail investor access to private markets

We are also identifying other policy issues that warrant regulatory attention and that have the potential to significantly improve investor outcomes. Additional updates will be shared as the year progresses.

Thank you for being part of our community and for your continued support of investor rights and fairness. We look forward to working alongside you in the year ahead.

Warm regards,

JP Bureaud, CEO, FAIR Canada

ADVOCACY IN ACTION

Working Toward a Fair, Timely, and Harmonized Complaint Standard

Canadian investors deserve a harmonized, fair, effective, and timely standard for complaint handling—regardless of where they live or which firm they use. Currently, standards vary by province and registration category, creating confusion and inconsistent protection.

To achieve harmonization, two critical steps are needed:

First, the Canadian Investment Regulatory Organization (CIRO) should promptly introduce dealer rules consistent with the Autorité des marchés financiers’ (AMF) requirement for dealers to respond to complaints within 60 days (or 90 days in exceptional circumstances). Since most Canadian investors work with a CIRO member, CIRO should lead efforts to harmonize and improve complaint resolution timelines. Its mission is to promote healthy capital markets “by regulating fairly and effectively so investors feel protected and confident investing for their futures”. Investor confidence depends on fair, consistent and timely complaint handling.

Second, the Canadian Securities Administrators (CSA) should prioritize a policy initiative to fully harmonize complaint handling obligations across all registrants and provinces, ensuring equal protection for all investors.

A harmonized national standard for complaint handling is essential to restoring fairness, and confidence for all Canadian investors. By aligning timelines and expectations across regulators, Canada can finally deliver the consistent protection investors deserve.

FAIR Canada Comments: The New Self-Certified Investor Prospectus Exemption

FAIR Canada recently submitted feedback to provincial securities regulators on a proposal that would allow individuals to invest in the exempt or private markets by "self-certifying" their education or work experience and signing a risk acknowledgement form. This process would permit issuers to distribute securities without providing them with the benefits and protections of a prospectus.

When developing this prospectus exemption, we emphasized the need for:

Clear qualification criteria, so firms and issuers cannot stretch or misinterpret who is eligible
Guidance on dealers’ core obligations — including Know Your Client, Know Your Product, suitability, and client-first duties — especially where annual investment limits apply
Data collection and review, so regulators can determine whether the exemption meets its intended objectives without eroding investor protections
Public reporting of compliance issues related to this exemption

Why it matters: Prospectus exemptions facilitate capital raising and increase access to exempt and private market investments but reduce disclosure and safeguards. The self-certified exemption should be limited to individuals who possess the genuine knowledge and experience necessary to protect themselves. Our recommendations aim to help regulators maintain the right balance between capital formation and investor protection.

Read our full comment letter here.

FAIR Canada Comments: CIRO’s OEO Guidance

We recently submitted a comment letter to CIRO on its proposed guidance on OEO accounts (or DIY investing accounts) used by millions of Canadians. Clear and consistent expectations for these services are essential, especially as more investors rely on online tools, screen prompts, and educational content.

In our letter, we:

Supported clearer expectations to strengthen confidence in DIY investing
Called for plain-language, timely disclosures tested with retail investors
Recommended annual reviews of investor tools and greater transparency about how these tools function and their intended purpose
Backed CIRO’s stance against limited product shelves, conflicts of interest, and practices that steer investors toward costlier or riskier choices
Raised concerns about gaps in suitability requirements, the use of gaming design features, and the influence of “finfluencers” operating without proper oversight

Why it matters: Stronger guidance promotes fairer communications and greater consistency across platforms, helping investors make more informed, confident decisions.

Read our full comment letter here.

REGULATORY BULLETIN

Modernizing Oversight: CSA–CIRO Guidance on Digital Advice

The CSA and CIRO recently issued new guidance to help finfluencers and the firms that partner with them understand how securities regulations apply to online financial content. The guidance clarifies when online posts may be considered advice, what disclosures are required, and how firms should oversee and manage relationships with finfluencers.

We have long advocated for stronger oversight of social media promotions, including paid endorsements of securities and cryptoassets. We support the CSA and CIRO in providing clear guidance to finfluencers, issuers and registrants to address those concerns.

While this is a positive step, more action is needed. Our recent comment letter outlines several recommendations, including requiring finfluencers who give advice to meet the same licensing and oversight rules as advisors, and limiting payments to one‑time referral fees rather than ongoing compensation that blurs the line into unregistered advice.

We encourage regulators to continue monitoring finfluencer activity and to pursue targeted reviews with transparent reporting.

Why it matters: Finfluencers operate outside the regulatory framework that governs licensed financial advisors. As more investors rely on these unregulated finfluencers for information, they gain broader access to content but face significant investor protection risks. Without oversight, investors are vulnerable to unsuitable advice, undisclosed conflicts of interest, or other potential harms.

For these reasons, the CSA and CIRO should go beyond guidance and actively monitor the activities of unlicensed finfluencers. This oversight is essential to ensure they are not violating registration requirements or putting investors at risk.

TOOLS YOU CAN USE

Report Cybercrime and Fraud – A New Way to Take Action

The RCMP has launched Report Cybercrime and Fraud, a new online system designed to make it easier for Canadians to report fraud and cybercrime. Whether you’ve lost money to a scam or witnessed suspicious activity, reporting can help police respond to your case and prevent others from becoming victims.

Managed by the RCMP’s National Cybercrime Coordination Centre (NC3) and the Canadian Anti-Fraud Centre (CAFC), the platform enables law enforcement to connect cases, disrupt threats, and bring cybercriminals to justice.

Why it matters: Only about 5% to 10% of fraud cases in Canada are reported, often due to embarrassment or lack of awareness. Reporting is a critical step in fighting fraud and cybercrime and protecting Canadians from financial harm.

Learn more and report an incident here.

WHAT'S NEW AT FAIR

FAIR Canada Welcomes Two New Board Members

We are pleased to announce that Brett Millard and Pat Dunwoody have joined FAIR Canada’s Board of Directors.

Brett Millard, Vice President of Business Development and Communication at FP Canada, brings over 20 years of experience advancing financial planning standards. As a former Chair of FP Canada’s Board and recipient of the FP Canada Fellow distinction, Brett has played a pivotal role in shaping financial planning and promoting financial literacy nationwide.

Pat Dunwoody, the founding Executive Director of the Canadian ETF Association (CEFTA), transformed the organization into a leading voice for ETFs in Canada, as industry assets grew from $50 billion to over $400 billion. Pat is widely recognized for her commitment to transparency, myth-busting, and investor education.

Their expertise and insights will strengthen FAIR Canada’s mission to champion investor rights and fairness in our capital markets.

FAIR Canada Team Celebrates the Season

This holiday season, our team gathered at Toronto’s historic Distillery District for a festive get-together. It was a wonderful opportunity to connect outside the office, share some holiday cheer, and reflect on the year’s achievements.

We are grateful for the dedication and collaboration that drive our work — and we look forward to continuing our mission to advance investor rights in the year ahead.

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