The Impact of CRM3 on Canadian Financial Services: What to Expect

When CRM3 (Client Relationship Model Phase 3) comes into effect in Canada, it’s not just another regulatory change - it will reshape the way advisors and wealth managers interact with their clients. Much like similar regulations in Europe, CRM3 puts a strong focus on cost transparency and building trust with investors.

The main change? Firms must now show all investment costs in clear dollar amounts - not just percentages. This means management fees, trailing commissions, and advisor charges will all appear on client statements in plain language. For clients, this creates a level of clarity they may never have experienced before. For advisors, it means demonstrating the value they provide in a way that goes far beyond picking investments. 

As AdvisorAnalyst wrote on June 23, 2025, “CRM3 might be the boldest transparency move in Canadian financial regulation. But it’s testing the limits of what the industry can deliver…” (AdvisorAnalyst, IIAC). This sums up the challenge: CRM3 sets a high bar for the industry, and meeting those expectations will take significant effort.

Regulators share this view. In October 2024, CIRO noted that the changes aim to protect investors by making fund costs clearer and aligning regulations. They acknowledged the impact will be broad but believe the benefits outweigh the costs (CIRO, Optimus SBR).

Can Clients Ask for Cost Details Anytime?

Yes. While CRM3 requires annual cost reporting, clients are likely to start asking for updates whenever they want - by phone, email, or during meetings. Advisors and their teams will need to make sure they can answer these questions quickly and accurately. This means having easy access to up-to-date information, which could mean changes in how client records are managed.

The Multi-Custodial Challenge

Many clients have assets spread across multiple firms, custodians, or even life insurance providers. Bringing all that information together in a clear, simple report is no small task. For advisors, this means:

• Finding a way to gather details from different sources.
• Making sure information is consistent and easy to understand.
• Meeting client expectations for a single, complete picture of their costs.

What This Means for Advisors

The firms that succeed under CRM3 will be the ones that make information easy for clients to understand and quick to access. Advisors should think about how to simplify reporting, provide clear explanations of fees, and build tools that allow clients to see their information whenever they want. This also means finding ways to integrate and consolidate data from other systems so the process feels seamless for both the advisor and the client. Done right, this can strengthen trust and make relationships more valuable over time.

Europe’s experience offers some insight. When MiFID II introduced similar rules, fees dropped, client expectations changed, and technology upgrades became essential. Canada may not see changes on the same scale, but the direction is clear: transparency will shape the future of wealth management.

In summary: CRM3 is more than a compliance requirement - it’s a chance to modernize, improve communication, and show clients real value. Firms that start preparing now will turn this challenge into an opportunity to lead.

- Rory

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Rory is founder of Navirum a financial service technology consulting company. Ex-Department of Finance (Irish Government), Merrill Lynch, & Bank of America.