Ethics, Conduct, and Standards

CIRO Rule 3100 is the standards-of-conduct rule that drives most ethics questions on the CIRE. Expect scenario-based questions applying the rule to a specific fact pattern. Memorize the rule structure — conflict of interest, personal trading, gifts, outside business activity, fiduciary duty.

Rules tested:CIRO Rule 3100CIRO Rule 3110CIRO Rule 3130NI 31-103 Part 13

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Standards of conduct (Rule 3100)

Duty of care: act in the client's best interest within the standard of a registered representative.
Duty of loyalty: avoid conflicts; disclose unavoidable ones; resolve disclosed conflicts in the client's favor.
Honesty and integrity: full disclosure of material facts in every recommendation.
Competence: only advise within your registration scope and skill.

Conflict of interest disclosure

Material conflicts must be disclosed at account opening and on an ongoing basis.
Examples: proprietary product sales, referral arrangements, related-issuer relationships.
Disclosure must be clear, specific, and timely — boilerplate is insufficient.
Conflicts that can't be addressed by disclosure must be avoided.

Personal trading and front-running

Personal trading in advance of a client order is prohibited.
Cooling-off period applies before and after client trades in the same security.
Reporting of personal accounts is mandatory; firm pre-clearance is common policy.
Front-running, scalping, and trading on inside information are all strictly prohibited.

Gifts, entertainment, and OBA

Gifts and entertainment subject to firm-level limits and reporting.
Outside business activities (OBA) must be pre-approved by the firm.
Any compensation outside the firm must be disclosed.
Acting as an executor, trustee, or POA for a client requires written firm approval.

Fiduciary obligations

Discretionary accounts trigger fiduciary duty obligations.
Managed accounts require an Investment Policy Statement and ongoing review.
Fiduciary duty does not require best-product, but does require best-process.
Breach of fiduciary duty is grounds for civil action plus regulatory discipline.

Anti-money laundering and PCMLTFA

PCMLTFA (Proceeds of Crime / Money Laundering and Terrorist Financing Act) statutory thresholds.
$10,000 cash transaction reporting threshold (single or aggregated).
$3,000+ EFT outside Canada triggers reporting.
Suspicious transaction reporting has NO threshold — any suspicion triggers reporting.
Record retention: 5 years from account closure for most records.

Exam traps

Trap:Treating boilerplate disclosure as sufficient for material conflicts.Fix:Material conflicts require clear, specific, timely disclosure. Generic terms-of-service language does not cut it.
Trap:Assuming the firm's compliance manual supersedes CIRO Rule 3100.Fix:Firm policy is the floor, not the ceiling. CIRO Rule 3100 always applies.
Trap:Missing that suspicious transaction reporting has NO dollar threshold.Fix:Cash threshold = $10K. EFT = $3K. Suspicious = any amount.

Memory hooks — Element 2

Ciroexam · CIRE 2026

→Rule 3100 = Standards of Conduct
→Material conflict → disclose at open + ongoing
→Personal trading in advance of client = forbidden
→PCMLTFA cash threshold = $10,000
→EFT outside Canada threshold = $3,000
→Suspicious transaction = NO threshold, always report
→OBA must be pre-approved