THE 360 NEWSLETTER

As part of our efforts to promote continuous improvement and business process efficiency, below you will find a summary of some of the most common deficiencies we observe and information to keep in mind when reviewing client information, documentation, and processing. The guidance and tips below will assist you in minimizing inquiries from your Compliance Officer and delays in trade processing.

Client-Focused Reform Training Modules

As a friendly reminder, all 3 of the Client-Focused Reform webinars (CFR training Module 1 – Conflict of Interest, Module 2 – Know Your Product, and Module 3 – Know Your Client) are available to all Investia Representatives and their staff (licensed and unlicensed assistants) now. Short videos are also available to help you in your day-to-day business and can be accessed directly via the Advisor Centre main page.

CFR training Module 1 is mandatory for all Representatives and their licensed and unlicensed staff, whereas Module 2 and Module 3 are both mandatory for all Representatives and their licensed staff. These modules should also be reviewed by your unlicensed staff to better support you.

Liquidity Needs

The new section of the NCAF/KYC Update Form related to the client’s liquidity needs, which is used to determine whether the client expects to use their Investia account assets to cover ongoing and short-term expenses, is a mandatory field. Please ensure that the form is completed in full before client authorization is obtained.

Liquid Alternative Funds and Exchanged Traded Funds

Please be reminded to complete the required proficiency and submit proof of completion for licensing approval before selling any of these products. For more details, please refer to the 360 memos below:

Liquid Alternative Mutual Funds – September 30, 2021 |Exchange Traded Funds – February 25, 2021

Order Affirmation

Please note that trades placed between 3:00 p.m. EST and trade cutoff at 4:00 p.m. EST will be processed on a best-effort basis. To ensure orders are in good standing, Representatives are encouraged to assess the trades through:

• Usage of the Advisor Dashboard to review clients under trade watch, outdated KYC profiles, and in certain transaction scenarios, OrderPRESS where you may preview the portfolio suitability prior to submitting the trade to be processed.
  
  
• Confirming that the trades are suitable to the most recently updated KYC profile and do not come up for any preliminary trade halts (for example, “Risk on Risk”). As a reminder, all orders that come up for order affirmation are required to be reviewed and authorized by your Branch Manager. We ask that you take the appropriate steps, in the interest of timeliness of order transmission, to ensure that all issues related to the trade watch (or reasons for the trade halt) be resolved prior to the placement of the trade.

Imaging Paperwork in a Timely Fashion

All paperwork in respect of client document processing (including notes in support of a transaction, remote account opening requirements, KYC updates, etc.) must be sent to imaging before the end of business day on the day the paperwork is processed as your Branch Manager is required to review documentation to validate client authorization for completeness and timeliness of processing.

KYC Compliant Update Date

Please ensure that the Compliant Update date inputted is the date on which the client(s) signed the NCAF/KYC Update Form. No KYC may be updated until client signature authorization is received, regardless of the tool used (Update Client Profile, OrderXPRESS, etc.).

Borrowing to Invest Strategies

Finally, any borrowing to invest strategy (i.e., mortgage refinancing, HELOC, leverage, etc.) must receive 2-tier dealer pre-approval. No investing with borrowed monies is permitted until pre-approval is received via email communication.

Should you have any questions or require additional clarification, please feel free to contact your Compliance Officer.