In this episode of Droit Talks About, host Hopeton Lindo is joined by Sherry Kurisinkal from Droit’s business development team to unpack CIRO’s updated Debt Securities Transaction Reporting Framework—better known as MTRS 2.0. Together, they break down what’s changing, who’s impacted, and what firms should do now to prepare.
From expanded reporting obligations and real-time data expectations to governance and vendor coordination, this conversation offers practical guidance for compliance officers, operations leads, and anyone navigating the evolving Canadian regulatory landscape.
Listen to the full episode below.
Full transcript below:
Hopeton: Hello and welcome to another episode of Droit Talks About where we bring clarity to the ever-evolving world of financial regulation. I’m your host, Hopeton Lindo. And today we are diving into CIRO’s Debt Securities Transaction Reporting Framework, otherwise known as MTRS 2.0, to help us make sense of what’s changing and, what firms need to do to stay compliant. I’m joined by Sherry Kurisinkal from Droit’s business development team who has spent the last few months engaging with Canadian clients on their new MTRS reporting obligations. Thanks for joining us, Sherry.
Sherry: Thanks, Hopeton. Happy to be here. Hopeton: Great. So let’s start from the top. For listeners who might not be familiar, what exactly is MTRS 2.0 and how does it differ from what we’ve had in place before? Sherry: Sure. MTRS stands for Market Trade Reporting System and it’s the mechanism the Canadian Investment Regulatory Organization or CIRO uses to collect transaction data for debt securities. CIRO, by the way, used to be IROC, the Investment Industry Regulatory Organization of Canada, and we might use them interchangeably in this conversation. The original system has been around since 2015 and it’s primarily been focused on IROC dealer members reporting their debt transactions. MTRS 2.0 is a major revamp that expands the scope, improves or attempts to improve data quality expectations, and aligns more closely with global best practices in trade reporting. Now this is not just for Canadian banks, but for any bank trading with a Canadian entity.
Hopeton: So this is not just a software upgrade. This is a fundamental, what sounds to me like it’s a fundamental shift in the rules, the scope of the instruments covered, and the firm’s now caught under this obligation, is that correct? Sherry: That’s exactly right. It’s a regulatory transformation, not just a tech upgrade.
Hopeton: Okay, so let’s dig into some of these changes. What are the key differences firms need to be aware of under this new MTRS 2.0?
Sherry: I would say there are a few big ticket items, the first one being the expanded scope under MTRS 2.0, both dealer members and non IROC regulated affiliates that trade in debt securities in Canada may have reporting obligations. This is a big change from the current framework. Secondly, the types of securities that need to be reported are expanding. This includes new categories of fixed income instruments such as commercial paper, structured notes and even certain asset backed securities. Real time reporting is a huge shift. MTRS 1.0 had T1 reporting, but 2.0 pushes firms towards near real time or end of day submission. More granular data is the fourth piece, CIRO is asking for richer data, including trade timestamps to the second counterparty identifiers and execution methods.
Hopeton: I just want to dig in a little bit around the, data aspect of what you were speaking about. Sounds like there’s a lot of new data elements. Does that mean firms need to overhaul their entire systems?
Sherry: In many cases, yes. Firms will need to assess their trade capture, order management and reporting infrastructure to ensure that they can provide all the required fields at the correct level of accuracy and timeliness.
Hopeton: Why now? Why is Ciro making these changes now? What’s driving these updates?
Sherry: I would say there are a few reasons. Globally, since the 2008 financial crisis, there has been a push for greater transparency in fixed income markets. Canada’s current framework has been relatively unchanged for a few years. And with other jurisdictions like the US via TRACE or Europe via MiFID II setting a higher bar, CIRO is looking to modernize MTRS 2.0 also aligns with CIRO’s broader mandate to enhance market integrity and surveillance capabilities. Aligning, with those of the US Regulators. More timely and detailed reporting helps regulators detect issues like insider trading, market manipulation, or detect systemic risk earlier.
Hopeton: Okay, that’s great. So let’s get practical around what you’re talking about. If I’m a compliance officer or an operations lead at a firm, what do I need to be doing today to get ready?
Sherry: That’s a great question and I would say just work with Droit, but more seriously, I would say that you have five steps to get through this process. Step one is the gap analysis. Start by comparing your current reporting capabilities with the new MTRS 2.0 requirements. What fields are you missing? What systems can’t handle the speed or the volume? Step two, it’s a data mapping exercise. Identify where each required field lives across your systems. That could mean looking at OMS systems, EMS systems or post trade platforms. This data mapping exercise that you have to do anyway will coincide, by the way, with the work to bring Droit on board. The third step is vendor coordination. If you use third party reporting solutions, engage them early to understand their timelines for market readiness. Vendors have different times for bringing their solutions to market and understanding that timing is important. And by the way, Droit have their eligibility solution live already with our report validation solution going live by the end of June 2025. Step four, think about governance. You need to put a formal project team in place. This isn’t just an OPS issue. It touches legal, IT compliance and front office. And then finally, step five, you need to go through the testing and validation process. CIRO is expecting to have a sandbox testing environment before full go live. I suggest you use it extensively.
Hopeton: Okay, so there are a number of steps here. What sort of deadline has been announced by CIRO, if any?
Sherry: So as of now, CIRO is targeting a phased rollout starting in 2025. The compliance deadline isn’t clear yet, but firms shouldn’t wait. The complexity means that early mobilization is key.
Hopeton: Sherry, you’re out in the market. You’re speaking to a lot of firms. What are some of the pitfalls to avoid or best practices to establish as these firms prepare for these changes?
Sherry: Absolutely. I would say the biggest pitfall is underestimating the complexity of the integration work, especially if your data is siloed. Another is assuming your vendor will handle everything. The firms still own the accuracy of the data submitted under their name. And finally, governance. If this gets stuck in middle management operations, it won’t get the visibility at the executive level that it needs.
Hopeton: Okay, so I’m going to put you on the spot here a little bit. Think about all the conversations that you’ve had, the feedback that you’ve had from firms. What would be your parting words of wisdom here or advice?
Sherry: I would say that this is a real opportunity for firms to future proof their trade reporting. MTRS 2.0 might seem like a burden now, but getting your systems and controls in order will not just help with the compliance, but also with internal analytics, risk management and market competitiveness.
Hopeton: Well, Sherry, thanks very much for all of those great perspectives. Thanks for joining us today and unpacking all of this.
Sherry: My pleasure. Thanks for having me.
Hopeton: So that will do it for this episode of Droit Talks About. If you found this helpful, and hopefully you did, be sure to subscribe and share it with your colleagues. We’ll include links to CIRO’s MTRS 2.0 updates and documentation in the show notes. I’m Hopeton Lindo. Thanks for listening.