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 household-level suitability determination must be supplemental to the account-level determinations.
From a compliance perspective, before registered firms can perform supplementary suitability determinations at the household level:
- the household members should have sufficient alignment of investment objectives to benefit from a household account suitability assessment,
- each individual who is not a minor within the household should be fully informed of the purpose of a household suitability determination and how it differs from account-level suitability determinations, and
- each individual who is not a minor within the household should agree to the household suitability determination.
These and many more topics are covered in the CSA’s Client Focused Reforms FAQs.
February 28, 2022