Appoint sufficient qualified Supervisors and Executives

Understanding the obligation

Rule 3905 distinguishes the appointment of Supervisors from the designation of Executives. The dealer must appoint enough Supervisors to supervise employees and Approved Persons properly, and designate enough Executives to support compliance with CIRO requirements. In each case, the dealer must consider the scope and complexity of its business.

The people designated to these roles must have the qualifications and authority needed to perform their assigned responsibilities fully. A title alone is not sufficient if the individual lacks appropriate competence, decision-making authority or a workable mandate. These CIRO roles should not be conflated with UDP and CCO designations under other instruments.

Requirements

• Appoint as many Supervisors as necessary for proper supervision, considering business scope and complexity.
• Designate as many Executives as necessary to ensure compliance with CIRO requirements, considering business scope and complexity.
• Ensure designated Supervisors and Executives possess the qualifications and authority needed for their assigned responsibilities.

Practical considerations Illustrative

Implementation examples, rather than additional express requirements.

• Define which functions, personnel and business activities each Supervisor oversees.
• Check for gaps or conflicts in assigned supervisory authority.
• Review the structure when the firm adds business lines, branches or personnel.

Potential evidence Illustrative

Examples of evidence; the cited provisions may not mandate these records.

• Supervisor and Executive designation records
• Role descriptions and delegated authority documents
• Qualifications or approval records
• Supervisory organization charts