CIRO Supervisor Exam

How the Supervisor Exam is set up

The Supervisor Exam is one multiple-choice paper: 90 questions in 3 hours, drawn from 9 elements. The syllabus cover (last updated May 29, 2025) splits the 90 questions into 60 standard questions and 30 item-set questions.

Standard questions

Each one stands alone. The question itself gives you everything you need to answer it.

Item-set questions

You get one scenario, such as a branch file, a client's situation or a supervisory review, followed by several questions about it. Each question is still multiple choice, but the facts you need are in the scenario.

The cover does not say how many scenarios the 30 item-set questions are split into, or how many questions each scenario carries.

In practice, a third of the exam is answered from scenarios. Three hours for 90 questions works out to 2 minutes a question, and an item set spends part of that on reading. Because several answers rest on the same facts, one misread detail, such as the day the first trade went through or the type of account, can cost you more than one question. Read the scenario once, carefully, and note the dates, the account type and who did what before you start on the questions.

A worked item set: a new account at a branch

We wrote this item set to show how the format works. It is not taken from CIRO's practice exam, and the people in it are invented. It tests Element 4 (account approvals) and Element 5 (account activity), the two largest elements. Read the scenario, answer the four questions, then open each answer to check your reasoning.

1. Question 1 · Element 4, outcome 4.1: prescribed timelines and business day approval

   Under section 3214, by when must a designated Supervisor approve Helen's account?

   1. A. Before Marc enters the first trade on Thursday
   2. B. Friday, one business day after the initial trade
   3. C. The following Thursday, five business days after the initial trade
   4. D. Within 25 business days of opening the account
   Show the answer and explanation

   Answer: B. Friday, one business day after the initial trade

   Section 3214(3) requires a designated Supervisor to approve each new account no later than one business day after the initial trade, which here is Friday. A is wrong because the rule lets the first trade come before approval; section 3214(4) even allows an interim approval procedure, as long as final approval follows within that one business day. C is not a deadline in the rule. D borrows the 25-business-day follow-up for missing documents in section 3213(2)(iii), which is a different obligation.

2. Question 2 · Element 4, outcomes 4.1 and 4.4: collecting client account records

   What should Anika do on Friday morning?

   1. A. Approve the account, because collecting know-your-client information is Marc's responsibility, not hers
   2. B. Approve the account and give Marc 25 business days to fill in the two blank fields
   3. C. Hold her approval and restrict the account to liquidating trades, transfers out and paying out funds or securities to Helen until she approves it
   4. D. Close the account and reverse Thursday's purchase
   Show the answer and explanation

   Answer: C. Hold her approval and restrict the account to liquidating trades, transfers out and paying out funds or securities to Helen until she approves it

   Risk profile and investment time horizon are required know-your-client information (section 3202(1)(iii)), and know-your-client information is one of the client account records defined in section 3210. Section 3214(2) says the designated Supervisor must not approve a new account until all client account records have been collected. Section 3214(5) says an account that is not approved after its initial trade must be limited to liquidating trades, transfers out, paying out funds or delivering securities to the client until final approval. A is wrong: section 3209(1) does make the Registered Representative primarily responsible for know-your-client, but that does not let the Supervisor approve an incomplete file. B misapplies the 25-business-day follow-up in section 3213(2)(iii), which is about chasing documents after opening, not approving an account with records missing. D goes further than the rule, which restricts the account rather than closing it.

3. Question 3 · Element 5, outcome 5.6: detecting concerning and suspicious account practices

   Anika decides to call Helen to confirm she authorized the trading in her account. Which flagged item most directly prompts that call?

   1. A. 14 trades in the month
   2. B. The junior mining stock at 45% of the account
   3. C. Four executed trades that were later cancelled and rebooked
   4. D. The margin call outstanding for three business days
   Show the answer and explanation

   Answer: C. Four executed trades that were later cancelled and rebooked

   Section 3945(2) lists what the daily and monthly supervision of retail accounts must detect. Item (vi) is "excessive transaction transfers and trade cancellations indicating possible unauthorized trading", and syllabus outcome 5.6 lists the same practice. The other three items are red flags too, but for other problems: excessive trading (iii), undue concentration (ii) and outstanding margin calls (xiv). Each needs its own follow-up, but only the cancellations are the red flag the rule ties to possible unauthorized trading, so they most directly prompt a call to confirm authorization.

4. Question 4 · Element 5, outcome 5.16: documenting reviews of client activity

   Helen confirms she authorized every trade. The cancellations corrected order-entry errors that Marc fixed the same day, and Anika is satisfied on that point. What must the record of her review show?

   1. A. Only her initials on the review report, since no problem was found
   2. B. The completed review, including her inquiry to Helen and how it was resolved
   3. C. Nothing of her own; a note in Marc's client file is enough
   4. D. A copy of an acknowledgement letter sent to Helen within five business days
   Show the answer and explanation

   Answer: B. The completed review, including her inquiry to Helen and how it was resolved

   Section 3927(2) requires the dealer to record and keep evidence of completed supervisory reviews, including details of inquiries about issues and their resolution, for the retention period in section 3803. Outcome 5.16 makes the same point: Supervisors must prepare and keep documentation of their assessments of client activity. A and C leave out the inquiry and its resolution. D applies the five-business-day acknowledgement letter for client complaints (section 3725(1)), but Helen has not complained. The concentration and the margin call still need their own follow-up; this question is only about the record.

Sections 3214 and 3945 are both on our Supervisor branch procedures cheat sheet, a free printable reference to Rule 3900 supervision, account approval, trade review, complaint handling and AML oversight at a branch.

Where the 90 questions come from

CIRO publishes the element weights as indicative question counts on the syllabus cover, not as percentages. Account approvals and account activity are the two largest elements, with 35 of the 90 questions between them.

For those two elements, start with the rules. The rules behind Element 4 are mostly in IDPC Rule 3200: account appropriateness (section 3211), opening new client accounts (3214), and the rules for order execution only, margin, derivatives, discretionary and managed accounts (3240 to 3281). Element 5 mostly follows Rule 3900, the supervision series: account supervision (3925 to 3927), daily and monthly review of retail accounts (3945 to 3948) and supervision of order execution only, derivatives, discretionary and managed accounts (3955 to 3973), plus the conditions for temporary holds on a vulnerable client's account (3222).

Who has to write it

An applicant for approval as a Supervisor must pass the Supervisor Exam (IDPC section 2603). If they supervise trading in securities, derivatives or managed accounts, they also need the exams required of the people they supervise: supervising retail Registered Representatives who deal in securities, for example, adds the Retail Securities Exam. Supervisors also need at least two years of relevant experience acceptable to CIRO, and a Supervisor who meets that requirement does not need the Canadian Investment Regulatory Exam (CIRE). Read our guide to who needs the Supervisor Exam.

A 30-day study plan

Our free 30-day Supervisor plan covers all nine elements in about 32 hours. It opens with supervisory structure and account activity (Elements 2 and 5), gives account approvals (Element 4) four days, and schedules full 90-question timed mocks on day 21 and day 26, each followed by a review day. See the 30-day Supervisor study plan.

Blueprint

Element-by-element breakdown

Parsed directly from the official CIRO syllabus. Every learning outcome maps to a specific element and weighted question count.

1. Element 1

   Free

   General regulatory framework

   11%

   This element begins with an understanding of the regulators in the Canadian investment services and the protections offered to consumers by way of legislation, such as the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorism Financing Act.

   • 1.1the role and authority of the Canadian Securities Administrators (CSA) and provincial/territorial securities and derivatives regulators.
   • 1.10the purpose and implications of the Proceeds of Crime (Money Laundering) and Terrorism Financing Act (PCMLTFA) and Regulations (PCMLTFA Regulations), including:
   • 1.11the purpose and implications of other applicable laws.
   • 1.12the Investment Dealer’s obligations to clients and others.
   • 1.13the client complaint requirements to specific situations relevant to Supervisors.
   • 1.14the recourse available to dissatisfied clients, including OBSI, CIRO arbitration and litigation.
   • + 17 more outcomes

   23 outcomes · 446 practice Q

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2. Element 2

   Supervisory structure: Investment Dealer responsibilities

   11%

   Element 2 requires the Supervisor to understand the obligations of an Investment Dealer when providing products and services to clients, including the role of Executives and the compliance department. Supervisors will also be required to analyze and apply to specific situations their general responsibilities, including the role of delegation and automation in supervision.

   • 2.1the requirement for an Investment Dealer to establish a supervisory system to supervise the activities of all its employees and Approved Persons to ensure compliance with CIRO Rules and securities laws. The supervisory system, at a minimum, must:
   • 2.10documented controls for delegation and apply those controls to specific situations relevant to a Supervisor.
   • 2.11the role of automation.
   • 2.12the Investment Dealer’s controls, policies and procedures for automation processes.
   • 2.2the product, due diligence obligations and exemptions, including:
   • 2.3the responsibility of Executives in the oversight of an Investment Dealer’s activities.
   • + 6 more outcomes

   12 outcomes · 230 practice Q

3. Element 3

   Specific supervision responsibilities in relation to the Investment Dealer business and operations

   10%

   In this section, the Supervisor needs to understand how an Investment Dealer’s supervisory structure can change depending on its business model. Element 3 also requires the Supervisor to analyze supervisory risks associated with different account, products and compensation structures.

   • 3.1the Investment Dealer’s responsibility to implement a supervisory system relevant to the scope and complexity of the business.
   • 3.10the supervisory risks associated with negotiated flat fees and referral fees.
   • 3.2the relationship between an Investment Dealer’s supervisory system and its internal controls.
   • 3.3the risks, opportunities and requirements for the Investment Dealer associated with each of the following business models:
   • 3.4the supervisory risks associated with each of the following client types:
   • 3.5the supervisory risks associated with each of the following accounts for both retail and institutional clients as applicable.
   • + 4 more outcomes

   10 outcomes · 205 practice Q

4. Element 4

   Specific supervision responsibilities in relation to account approvals

   22%

   Element 4 requires the Supervisor to understand the requirements for account approvals for a range of accounts, including order execution only (OEO) accounts, discretionary accounts, managed accounts and derivatives accounts. Supervisors will need to apply many of these requirements to specific situations relating to account opening.

   • 4.1account approval requirements.
   • 4.10other matters required by a derivatives trading, clearing or issuing entity.
   • 4.11the client’s cumulative loss limits:
   • 4.12the purpose and content of a Letter of Undertaking as an alternative to trading agreement for institutional clients only.
   • 4.13the requirements for the supervision of managed accounts. Consider the need to:
   • 4.14the purpose and content of the managed account agreement.
   • + 15 more outcomes

   21 outcomes · 320 practice Q

5. Element 5

   Specific supervision responsibilities in relation to account activity

   17%

   Element 5 continues the theme of Element 4 but now requires an understanding of the ongoing risks of different accounts. It requires the Supervisor to analyze situations to identify what risks may be present and apply appropriate procedures to mitigate or respond to those risks.

   • 5.1different approaches to supervision, including:
   • 5.10the direct market access (DMA) account and supervision requirements for institutional clients, including algorithmic trading.
   • 5.11the OEO account services exemptions and requirements.
   • 5.12CIRO requirements for handling derivatives accounts, including the need to appoint one or more alternate Supervisors where continuous supervision of derivatives trading activity is required
   • 5.13to specific situations relevant to a Supervisor the requirements specific to retail clients holding a derivative account to detect:
   • 5.14the use of policies and procedures to specific situations relevant to a Supervisor.
   • + 10 more outcomes

   16 outcomes · 165 practice Q

6. Element 6

   Specific supervision responsibilities in relation to activities of Approved Persons

   9%

   Element 6 requires the Supervisor to analyze specific situations and risks that they may encounter during account opening and ongoing account activities. It also requires them to apply the requirements relating to product due diligence, know-your-client (KYC) and suitability determination to specific situations and understand the importance of client education and information.

   • 6.1specific situations the Supervisor’s responsibility relating to permitted and prohibited activities of Approved Persons.
   • 6.2specific supervisory responsibilities relating to account opening.
   • 6.3to specific situations the Supervisor’s responsibility relating to the suitability determination for retail and institutional clients.
   • 6.4specific supervisory responsibilities relating to account activity once opened.
   • 6.5the product due diligence and KYC obligations on:
   • 6.6the role of the Supervisor in ensuring Approved Persons educate clients in the purpose of:
   • + 2 more outcomes

   8 outcomes · 85 practice Q

7. Element 7

   Specific supervision responsibilities in relation to trading and market rules

   7%

   A Supervisor is expected to understand and be able to apply the obligations under the Universal Market Integrity Rules (UMIR) in Element 7. They are also required to apply the appropriate regulatory standards to the supervision of order placement and gatekeeping responsibilities.

   • 7.1the market rules, including UMIR,
   • 7.2the applicable regulatory standards with respect to the review, acceptance and approval of orders to specific situations relevant to a Supervisor.
   • 7.3the obligations on the Investment Dealer regarding its trading supervisory systems.
   • 7.4the obligations on the Investment Dealer regarding its regular review of compliance with respect to the following provisions for trading on a marketplace, where applicable to their lines of business:
   • 7.5the obligations on the Investment Dealer regarding its risk-based supervision system, which reflects:
   • 7.6the gatekeeping responsibilities and applicable regulatory requirements to specific situations relevant to a Supervisor, including:

   6 outcomes · 65 practice Q

8. Element 8

   Specific supervision responsibilities in relation to advertisements, sales literature and communications

   8%

   This element requires a Supervisor to understand the requirements when an Investment Dealer or Approved Person communicates with a client, advertises products and services or produces research documentation. It also requires the Supervisor to apply these requirements to specific situations relevant to a Supervisor.

   • 8.1the requirements that specifically address the review and supervision of advertisements, sales literature and client correspondence relating to its business.
   • 8.2to specific situations, relevant to a Supervisor, the requirements for an Investment Dealer to ensure that the following items are approved by a designated Supervisor before use or publication:
   • 8.3the requirements relating to research report disclosures to specific situations relevant to a Supervisor. Consider the following disclosures:
   • 8.4specific situations relating to the supervision of conduct of Investment Dealers and relevant individuals when producing research reports.

   4 outcomes · 45 practice Q

9. Element 9

   Specific supervision responsibilities in relation to risks

   6%

   Element 9 requires a Supervisor to analyze a variety of risk factors relevant to the Investment Dealer and apply supervisory requirements to a variety of retail distribution risks.

   • 9.1the guidelines for business location supervision, including:
   • 9.2additional risk factors and the potential impact on the Investment Dealers and its clients of using different business locations.
   • 9.3supervisory requirements to retail distribution risks, including advisory services and fully discretionary managed products to specific situations relevant to a Supervisor.

   3 outcomes · 35 practice Q