In an effort to simplify part of the annual fee model for Dealer Members, IIROC has proposed a single $22,500 Minimum Fee category to replace the existing $15,000 and $27,500 Minimum Fee categories as well as eliminating the Total Allocated Cost Element upon which the fee is calculated.

Under the current model, volatility in the change in allocated costs could result in a different minimum fee category in different years. This lack of predictability may create budgeting challenges, and it is unfair for a small change in allocated costs to result in a higher fee category ($27,500 fee versus a $15,000 fee).

In determining the proposed fee amount, IIROC considered the 4-year average fee payment by Dealer Members and found that most pay more than $22,500 and would therefore benefit from a drop in fees. Those that had an average of less than that would only be slightly impacted by the proposed change. A single fee category would not necessarily increase the fee burden on the lowest-revenue Dealer Members.

Of the alternative approaches considered, IIROC believes that this is the least complex and most equitable.

IIROC anticipates that the proposed changes to the Minimum Fee would become effective April 1, 2018, following a comment period that closed on February 5, 2018.

DISCLAIMER: This publication is intended to convey general information about legal issues and developments as of the indicated date. It does not constitute legal advice and must not be treated or relied on as such. Please read our full disclaimer at