CRM3 and Total Cost Reporting: What Canadian Wealth Firms Need for the First 2027 Client Reports

CRM3, officially Total Cost Reporting (TCR), is a Canadian Securities Administrators (CSA) rule, mirrored in CIRO’s dealer rules, that took effect on January 1, 2026. Dealers and advisers must now report the ongoing embedded costs of investment funds, in dollars, alongside direct charges. The first annual reports under the new rules cover calendar year 2026 and reach clients in 2027.

Updated: November 1, 2026

CRM3 / Total Cost Reporting at a glance

Also called	CRM3, TCR
Rule makers	CSA (amendments to NI 31-103), CIRO (harmonized dealer rules), CCIR (parallel guidance for segregated funds)
In force	January 1, 2026 (CSA and CCIR notice, April 2023; OSC approval of CIRO amendments, July 2025)
First client reports	Annual reports covering the year ending December 31, 2026, delivered in 2027 (CSA and CCIR notice, April 2023)
Report affected	Annual Report on Charges and Other Compensation (ARCC)
New disclosures	Fund expenses in dollars; direct investment fund charges; total costs of investing; Fund Expense Ratio (FER) for each fund
FER	Management expense ratio (MER, which includes trailing commissions) + trading expense ratio (TER)
Products in scope	Investment funds, including mutual funds, ETFs and scholarship plans; segregated fund contracts through CCIR guidance. Labour-sponsored and prospectus-exempt funds are excluded for now (CSA and CCIR notice, April 2023)
Who’s affected	Investment dealers, mutual fund dealers, portfolio managers, investment fund managers (who provide the data), insurers offering segregated funds

How we got here: CRM2, the Client Focused Reforms, and CRM3

CRM2, phased in between 2014 and 2016, required dealers to give clients annual reports on the fees they pay directly and on account performance. The Client Focused Reforms (2021) then strengthened conflicts-of-interest, know-your-client, know-your-product and suitability obligations. CRM3 (Total Cost Reporting) closes the gap CRM2 left: the ongoing costs embedded inside funds, which clients never saw in dollars until now (CSA and CCIR notice, April 2023; OSC notice approving CIRO’s enhanced cost reporting amendments, July 2025).

Clients’ annual reports now include the Fund Expense Ratio (FER) for each fund they hold, which combines the Management Expense Ratio (MER) and the Trading Expense Ratio (TER), alongside the dollar cost of fund expenses and the firm’s own charges.

What your clients will see in their 2027 reports

Each client’s annual report now shows, in dollars, what they paid in fund expenses across their holdings, any direct fund charges such as redemption or short-term trading fees, and a single total cost of investing that combines those with the fees paid to the dealer. A table lists the Fund Expense Ratio for each fund held. None of these are new costs, but for many clients it will be the first time they see them as one number.

What CRM3 will change in client conversations

The disclosure change is small on paper and large in conversation. A client who has never seen fund expenses in dollars is being handed a number for the first time, and the questions that follow are predictable enough to prepare for:

• Why have my reported costs gone up? The reported figure is new; the cost is not. Fund expenses were always paid, and the rules now require them to be shown in dollars.
• Are these new fees? No. Nothing has been added. What changed is the disclosure.
• How much goes to my advisor, how much to the dealer, and how much to the fund manager? The total combines direct charges paid to the dealer with expenses paid inside the fund, and clients will want the split explained.
• Are these costs already reflected in my returns? Yes. Fund performance has always been reported after fund expenses are deducted.
• Why do I hold this fund rather than a lower-cost alternative? A product selected for a reason now carries a visible price tag, and the reason needs to be on hand.
• What services am I getting for the total I pay? The hardest of the six, and the one that decides how the conversation ends.

That last question is where the value of advice has to be stated rather than assumed. For most households the answer is a list: financial planning, tax coordination across accounts and family members, retirement income and decumulation advice, risk management and insurance review, behavioural coaching that keeps clients invested through volatile markets, and proactive service between reviews. Firms that can describe that work by client segment, with examples, go into 2027 conversations in a different position than firms improvising at the desk.

The first 90 days after statements land

Expect three things once 2026 reports go out. First, more client questions, mostly variations of “why are my fees higher?”, landing with advisors and service teams at the same time. Second, advisors needing to prepare for fee conversations: which households hold high-FER products, who has already called, and what was said. Third, data reconciliation: figures from fund manufacturers, dealers and custodians that don’t line up and need tracing before a client is answered.

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The operational challenge for wealth firms

The figures on a single client report are assembled from data that lives in at least six places:

• Fund managers and cost-data providers, who supply the fund expense inputs
• Custodians, who hold the positions and transactions
• Portfolio accounting and portfolio management systems, which carry valuations and holdings history
• Dealer back-office platforms, which carry the direct charges
• Regulatory reporting systems, which perform the calculation and produce the annual report
• CRM and client-service platforms, where the conversation with the client actually happens

A CRM is not the source of any regulatory calculation and should not be presented as one. The reporting system of record performs the calculation and produces the annual report. The operational challenge is different: connecting accurate cost data to client, household, advisor and workflow context, so the firm can answer for a number it did not calculate.

Where those connections are missing, the same six problems show up every reporting cycle:

• Incomplete client views, where no single screen shows a household’s holdings, costs and relationship history together
• Manual reconciliation between fund, custodial and back-office figures that do not agree
• Inconsistent advisor preparation, where the quality of a fee conversation depends on who is having it
• Slow responses, because answering one client question requires three systems and two colleagues
• Weak exception and correction workflows, so a disputed figure has no tracked path to a resolution
• Limited management and compliance visibility into what clients are asking and how it is being handled

Where Salesforce Financial Services Cloud fits

Salesforce FSC is built for financial services and gives advisors one place to work from client information. With custodian and fund-data integrations, it brings data from multiple custodians, funds and strategies together so advisors can answer client questions quickly and accurately.

Key Salesforce features that support CRM3 readiness:

• One client view: with custodian and fund-data integrations, FSC brings holdings and cost data together at the household level, so an advisor can see a client’s total cost of investing next to the relationship history.
• Inquiry tracking: log every CRM3 question as a case, route it, and report on volume and themes.
• Advisor prep: Agentforce can summarize a household’s cost picture and prior conversations before a review meeting.
• Repeatable cycle: Total Cost Reporting recurs every year; Orbit managed services keeps the data flows, reports and automation maintained.
• Role-based access and auditability: role-based access to client and cost data, workflow history on who did what and when, and records that support the firm’s own audit and supervision. These controls have to be designed, configured and governed; implementing Salesforce does not produce them on its own and guarantees nothing.

FSC supports a firm’s compliance program; it does not replace the dealer’s reporting system that produces the annual report.

Turning greater transparency into client value

Total Cost Reporting is a disclosure obligation, but it also forces a conversation most firms have wanted to have better. A firm that prepares for it well gets clearer fee conversations instead of defensive ones, a reason to demonstrate the value of advice rather than assert it, an early read on which clients need proactive contact before they call, an occasion to review whether products and service models are still appropriate for each segment, and better information for personalized guidance.

Doing that at scale is where a platform helps. When it is connected to trusted source systems, Salesforce FSC is where that preparation becomes repeatable: segments defined once, talking points and service summaries available at the point of conversation, outreach tracked, and themes visible to management. The value comes from the preparation and the data behind it; the platform is what keeps it from depending on individual effort.

Staying ready as Canadian rules keep changing

CRM3 won’t be the last change. Total Cost Reporting repeats every year, the CSA has said it may consider proposals to extend it to prospectus-exempt and labour-sponsored funds, and Canadian firms are also working through new expectations on AI and data. Each change touches the same systems: client data, integrations, reports, and increasingly the AI that sits on top of them.

Two kinds of ongoing support help firms keep up without starting a new project every time:

• Keep the platform current. Orbit Salesforce managed services handles day-to-day administration, release readiness, data quality, and monitored custodian and portfolio integrations. When reporting requirements change, the work to update fields, reports and workflows is already in the plan. Orbit doesn’t make a firm compliant; it maintains the access controls, audit trails and documented changes that support the firm’s own compliance program.
• Re-check the AI every time something changes. If your firm uses Agentforce or other AI to answer client fee questions or prepare advisors, those answers need to stay accurate as the rules and data change. AI governance consulting runs an assurance check after each material change, covering security, output quality and cost, and gives you an evidence report of what passed and what didn’t.

A practical CRM3 readiness agenda

Eight actions, in the order most firms find useful, ahead of the first reports reaching clients in 2027:

1. Validate your fund-cost and holdings data sources, including what each provider supplies and how gaps are handled.
2. Confirm in writing which system performs the regulatory calculation and which produces the annual report.
3. Review sample reports internally, before any client sees one.
4. Identify the clients with the highest expected dollar costs, who are the most likely to call.
5. Prepare advisor talking points, starting from the point that greater visibility is not new fees.
6. Document the services and value your firm delivers, by client segment.
7. Establish workflows for questions, discrepancies, corrections and complaints, with owners and timelines.
8. Assess whether your CRM gives advisors enough context to answer a cost question without leaving the record.

Frequently asked questions

What is CRM3?

CRM3 is the industry name for Total Cost Reporting, the CSA and CIRO rules in force since January 1, 2026 that require dealers and advisers to show clients the ongoing costs of their investment funds in dollars. It’s called CRM3 because it follows CRM2, the cost and performance reporting rules phased in from 2014 to 2016.

What is Total Cost Reporting?

A CSA rule, mirrored by CIRO, requiring dealers and advisers to report the ongoing embedded costs of investment funds in dollars, alongside direct charges, in clients’ annual reports. It took effect January 1, 2026.

When will clients receive the first CRM3 statements?

The first annual reports cover calendar year 2026 and are delivered to clients in 2027.

What is the Fund Expense Ratio (FER)?

The FER is a fund’s management expense ratio (MER) plus its trading expense ratio (TER). The MER includes any trailing commissions.

Does Total Cost Reporting apply to segregated funds?

Yes, through guidance from the Canadian Council of Insurance Regulators (CCIR). The guidance is not binding on its own, so each jurisdiction implements it through its own rules, but it applies similar cost and performance reporting to segregated fund contracts.

Is CRM3 an official name?

No. “CRM3” is industry shorthand. Regulators call it Total Cost Reporting, or the enhanced cost disclosure requirements.

How can Salesforce Financial Services Cloud help with CRM3?

With custodian and fund-data integrations, FSC puts each household’s cost data next to its relationship history, tracks client fee questions as cases, and supports advisor prep. FSC does not replace the dealer’s reporting system that produces the annual report.

How can firms get ongoing support as Canadian regulations change?

Managed services such as Navirum’s Orbit keep Salesforce data, integrations, reports and audit trails current as requirements change, in support of the firm’s own compliance program. Firms using AI with clients can add recurring AI assurance checks after each material change to confirm outputs stay accurate, secure and cost-controlled.

Navirum has implemented Salesforce for Canadian and US wealth firms since 2018. If you’re preparing for the first CRM3 reporting cycle, start with Orbit managed services for ongoing platform support, AI assurance if AI touches client cost questions, or Agentforce for Wealth Management. For a new build, see our strategic consulting and Salesforce financial services consulting.

Sources

• CSA and CCIR Notice of Publication: Total Cost Reporting for Investment Funds and Segregated Funds (April 20, 2023)
• OSC: CSA and CCIR notice, including CCIR segregated fund guidance
• OSC Notice of Commission Approval, July 3, 2025: CIRO Amendments Respecting Enhanced Cost Reporting (effective January 1, 2026)

This article is general information about Canadian regulatory requirements and is not legal, compliance or investment advice. Confirm how Total Cost Reporting applies to your firm with your own compliance and legal advisors.

Need help preparing for CRM3 in your firm?

Navirum helps Canadian wealth firms get client data, custodian integrations and reporting ready for the first Total Cost Reporting cycle, then keeps everything current as the rules change. A practical starting point is an assessment of how client, custodial, portfolio and reporting information moves across your environment today, and where that leaves advisors when a client calls about a number. Tell us where you are and we will recommend the right next step.

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