Category: Client-Focused Reforms (CFRs)
Mar 31, 2023 | Client-Focused Reforms (CFRs), Investment Funds, Regulatory Compliance
On March 20, 2023, the New Self-Regulatory Organization of Canada (New SRO) published its New SRO Compliance Priorities Report for 2022/2023: Helping Firms with Compliance. The report highlights what the New SRO believes are issues and challenges faced by the...
Feb 28, 2023 | Client-Focused Reforms (CFRs), Regulatory Compliance
Since the introduction of the new conflict of interest (COI) requirements in June 2021, the Canadian Securities Administrators (CSA) and New Self-Regulatory Organization of Canada (New SRO) have been actively testing how well the industry has adapted to the...
Jun 30, 2022 | Client-Focused Reforms (CFRs), Regulatory Compliance
As you may know, many of the provincial regulators including staff at the Ontario Securities Commission (OSC), are currently conducting a wide sweep of registrant firms. This sweep is meant to review how the industry has adapted to and applied the conflict of interest...
Jun 30, 2022 | Client-Focused Reforms (CFRs), Regulatory Compliance
Identifying OAs: Regulators have been busy with the implementation of the client focused reforms (CFRs) and the recent amendments to National Instrument 33-109 Registration Information (NI 33-109) and National Instrument 31-103 Registration Requirements, Exemptions...
May 31, 2022 | Client-Focused Reforms (CFRs), COVID-19, Investment Funds, Regulatory Compliance
Despite the impending consolidation of IIROC and the MFDA discussed earlier in this bulletin, staff of the Canadian Securities Administrators (CSA) are required to assess both self-regulatory organizations (SROs) and their respective investor protection funds (IPFs)...
May 31, 2022 | Client-Focused Reforms (CFRs), FAQs, Regulatory Compliance
Since the enhancements introduced as part of the Client Focused Reforms (CFR) came into force in 2021, the Canadian Securities Administrators (CSA) has been providing the industry with additional guidance by publishing an FAQ with a few updated responses to questions...
Apr 29, 2022 | Client-Focused Reforms (CFRs), Regulatory Compliance
In early March, a number of registrants were selected by staff at the Ontario Securities Commission (OSC) to undergo a focused review on their conflict of interest policies and procedures. The OSC is searching for information on how firms have operationalized the...
Apr 29, 2022 | Client-Focused Reforms (CFRs), Regulatory Compliance
On April 21, the Investment Industry Regulatory Organization of Canada (IIROC) released another version of proposed amendments to its rules relating to the futures segregation and portability customer protection regime. As noted in our August 2021 bulletin, the...
Apr 29, 2022 | Client-Focused Reforms (CFRs), FAQs, Investment Funds, Regulatory Compliance
You just got a formal request from the Ontario Securities Commission (OSC) that they would like to come by for a visit, accompanied by a request for all the inner workings of your firm, what do you do?! First, respond. Second, get ready, any regulatory review will be...
Mar 31, 2022 | Client-Focused Reforms (CFRs), Cyber-security and Data Privacy, Investment Funds, Regulatory Compliance
Earlier in March, the Investment Industry Regulatory Organization of Canada (IIROC) released its 2021/2022 Compliance Priorities Report, outlining its past actions and current issues that are impacting IIROC-regulated firms that should be a compliance focus for those...
Mar 31, 2022 | Client-Focused Reforms (CFRs), Investment Funds, Regulatory Compliance
At a Glance: Earlier this month, the Ontario Divisional Court decision in Boal v. International Capital Management Inc. provided some clarity on the scope and nature of the duty owed by financial advisors to their clients, and their obligations under the client...
Mar 31, 2022 | Client-Focused Reforms (CFRs), Regulatory Compliance
If not already completed, firms with a December year end should turn their attention to the required annual report from the Chief Compliance Officer. National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations requires that a...
Mar 31, 2022 | Client-Focused Reforms (CFRs), FAQs, Investment Funds, Regulatory Compliance
Answer: As set out in National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (31-103), as a registrant you are now required to follow all the new KYC and suitability requirements. Section 13.3(2) of NI 31-103 provides,...
Feb 28, 2022 | Client-Focused Reforms (CFRs), Corporate Finance, Investment Funds, Regulatory Compliance
A number of CSA jurisdictions have begun their promised registrant reviews relating to the client-focused reforms. These jurisdictions have sent out very extensive questionnaires relating specifically to the conflicts of interest provisions that came into force at the...
Feb 28, 2022 | Client-Focused Reforms (CFRs), FAQs
Answer: The regulatory guidance on this topic is similar to the answer above; registered firms can perform a suitability determination at a household level, but only if they also separately make an account-level suitability determination. In other words, the...
