Keeping Your RRSP as a US Resident: SEC Rules and Non-Resident Brokerages
Tax law and brokerage compliance are two completely different things. From a tax standpoint, leaving your RRSP untouched in Canada when you move to the US is almost always the right move: it's exempt from Canada's departure tax, and the Canada-US tax treaty shelters its growth from annual US federal tax. The rude surprise happens weeks after you update your mailing address to the US and your Canadian bank or robo-advisor sends a letter saying your account has been placed in "liquidate-only" mode or must be transferred out within 60 days.
Why non-registered accounts get closed, while RRSPs have a special SEC exemption
Under the US Securities Exchange Act of 1934 and state "Blue Sky" securities laws, a Canadian investment dealer that is not registered with the US SEC and FINRA (and registered in the specific US state where you live) is generally barred from executing trades for a person physically residing in the United States. That is why almost every Canadian retail brokerage refuses to maintain a non-registered taxable account once you move to the US: before you leave, you normally transfer non-registered shares in-kind to a cross-border brokerage like Interactive Brokers or a US custodian (after accounting for Canada's departure tax).
For RRSPs, RRIFs, and LIRAs, however, you cannot transfer the account to a US brokerage without collapsing the RRSP and triggering a 25% Canadian lump-sum withholding tax plus full US income tax. Recognizing that problem, the US Securities and Exchange Commission issued a formal exemptive order in June 2000 (Release No. 34-42906, alongside Rule 15a-6) permitting Canadian broker-dealers and members of CIRO (formerly IIROC) to continue managing and executing unsolicited or self-directed trades inside Canadian tax-deferred retirement accounts (RRSPs, RRIFs, LIRAs, LIFs) for individuals who are present or resident in the US, and most US states adopted parallel model exemptions through NASAA.
How Canadian institutions typically handle US-resident RRSPs
Because each firm sets its own internal compliance policy (and policies change periodically), Canadian institutions generally fall into three buckets once you file a Form W-9 (confirming you are now a US person) and provide a US residential address:
1. Full self-directed RRSP trading for US residents
Certain dedicated cross-border advisory practices and select self-directed discount brokerages rely on the SEC/NASAA Canadian retirement exemption to allow ongoing buys, sells, and rebalancing of stocks and ETFs inside an RRSP or RRIF while you reside in most US states.
2. "Hold or Sell Only" (no new buys or switches)
Many big-five Canadian bank discount brokerages allow you to keep your RRSP open with a US address, collect dividends, and place sell orders or request withdrawals, but block new buy orders (and in some cases block Canadian mutual fund purchases because Canadian mutual fund prospectuses cannot be distributed to US residents).
3. Robo-advisors and mutual-fund-only dealers (often require transfer out)
Discretionary robo-advisors that automatically rebalance portfolios and mutual-fund-only platforms often cannot service US residents at all, giving you 30 to 90 days to transfer your RRSP in-kind to another Canadian institution (via CRA Form T2033, which is a tax-free institution-to-institution RRSP transfer).
What to do inside your RRSP before your departure date
Because your trading flexibility inside an RRSP may be restricted once your US address is on file, the weeks before you leave Canada are the best time to set up your RRSP for a multi-year US stay:
- Ask your current brokerage directly before you move: Call and ask specifically: "Once I update my residency to [US State] and submit a W-9, can I still place buy and sell orders for ETFs inside my self-directed RRSP, or does the account become sell-only?" If they are sell-only or require closure, initiate a tax-free T2033 transfer to a non-resident-friendly Canadian institution while you still have a Canadian address.
- Consolidate into a single, low-maintenance all-in-one ETF (if sell-only): If your RRSP will be in hold/sell-only mode while you are in the US, holding 15 individual stocks or sector funds means you can never rebalance. Consolidating into a single globally diversified asset-allocation ETF (with automatic dividend reinvestment/DRIP enabled, if supported for non-residents) lets the portfolio rebalance itself internally without you needing to place a buy order. (Remember: PFICs inside an RRSP are generally exempt from Form 8621 under Treas. Reg. 1.1298-1(c)(4).)
- Reset your cost basis inside the RRSP if moving to California, New Jersey, or Pennsylvania: As explained in California and State Tax on Your RRSP and TFSA, selling and immediately repurchasing appreciated holdings inside your RRSP before moving to California steps up the cost basis of those holdings at $0 Canadian tax so pre-move gains aren't taxed by California later.
Canadian brokerage policies for US residents (2026)
| Institution | Retain Existing RRSP / RRIF? | Rebalancing Trades Allowed? | Non-Registered & TFSA Policy |
|---|---|---|---|
| Questrade | Yes (with W-9 & US address on file) | Yes (self-directed ETFs & stocks) | Non-reg placed in liquidation-only; close TFSA before departure. |
| TD Direct Investing | Yes | Yes (typically via phone/representative) | Non-registered accounts restricted from new purchases. |
| RBC Direct Investing | Yes | Yes (depending on US state of residence) | Non-registered accounts must be closed or transferred out. |
| BMO InvestorLine | Yes (case-by-case state rules) | Often restricted to hold/liquidate-only | Non-registered accounts required to close upon US residency. |
| Wealthsimple | No (supports Canadian residents only) | No | All accounts must be transferred out or liquidated before moving. |
Not tax, legal, or investment advice: brokerage policies and state-level Blue Sky exemptions vary by firm and US state; confirm directly with your custodian before relocating. Model your future withdrawal rates on the RRSP Withholding Tax Calculator and check your other accounts on the PFIC Risk Checker.