THE 360 NEWSLETTER

Updated Compliance Policies & Procedures Manual (“CPPM”) – June 2022 Version

Compliance June 16, 2022
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We are pleased to announce the release of an updated version of Investia’s Compliance Policies & Procedures Manual (“CPPM”), reflective of policy changes and enhancements arising from internal, regulatory and harmonization developments made over the past year. 

This new edition of the CPPM will be uploaded onto the Investia Advisor Centre on Monday, June 20 under the Guides & Training / Compliance section and will replace any former versions.

For ease of reference, the list of material changes in the CPPM are outlined in the table below:

Section

Description of Change

Chapter 1: Section II, D)
  • Update of Coordinator-Corporate Branch Manager title to Compliance Manager

Chapter 2: Section I, D)

  • NEW: Proficiency Requirements for Exchange Traded Funds (“ETF”)
  • NEW: Proficiency Requirements for Liquid Alternative Mutual Funds (“ALTs”)

Chapter 2: Section I, F)
  • Update to Errors and Omissions Insurance (“E&O”) section: “Representatives are responsible for reviewing their insurance coverage to ensure that it meets their business requirements”

Chapter 2: Section II, F)
  • Updated Business Titles section

Chapter 2: Section III, A)
  • Updated Positions of Influence section

Chapter 3: Section I
  • Updated Head Office Address for Privacy Officer

Chapter 4: Section I, A)

  • NEW Risk Profile section
  • NEW Risk Capacity section
  • NEW definition for Risk Tolerance
  • Updated Asset Allocation section

Chapter 4: Section I, K)
  • Updated Sales Charge Policy

Chapter 4: Section II, B)
  • Amendment: Statement of Disclosure (“SOD”) renamed Relationship Disclosure Information Document (“RDID”)

Chapter 4: Section IV, F)
  • NEW Vulnerable Clients section

Chapter 4: Section IV, G)
  • NEW Temporary Holds on Client Accounts section

Chapter 4: Section IV, H)
  • Updated Trusted Contact Person section

Chapter 5
  • NEW Know-Your-Product section

Chapter 6: Section I, F)
  • NEW Exchanged Traded Funds (“ETF”) section

Chapter 7: Section I
  • Amendment: Contributions to an individual’s TFSA/RRSP/group RRSP/pension account can be made through a corporate bank account; however, Investia reserves the right to require the following:
  • Dealer consent;
  • Imprinted corporate void cheque;
  • Signature(s) of individual(s) authorized to sign on behalf of the corporate bank account; and
  • Banking resolution for the corporate entity indicating the individual(s) who has signing authority over the corporate bank account.

Chapter 8: Section II and III
  • Amendment to New and Transfer in Leverage Account Procedures section.
  • New and transfer in leverage requests must be sent to compliance@investia.ca for Head office compliance review.
  • To comply with cybersecurity guidelines, LARFs, KYCs, Loan applications and any supporting documentation must be sent directly to imaging and be referenced in the email or JIRA request. Conditional on documents being sent in good order, a member of the compliance team will provide a response within a 14-day window to issue decision on review.

 

Chapter 9: Section I
  • Updated Head Office Address for Compliant Handling

Chapter 10: Section I
  • NEW Disclosure Requirements to Clients

Chapter 10: Section II
  • Amendment to Business Promotion Items and Activities section

Chapter 10: Section V
  • Updated Deficient Forms (Signature Falsification) section

Chapter 10: Section X
  • Amendment to Uniformity of KYC section: With an increased regulatory focus on KYC uniformity and investment patterns, the Investia Compliance Department will generate a report on a monthly and semi-annual basis to conduct periodic reviews of the Representatives’ book of business

Chapter 12: Section II, C)
  • Amendment to the Requests for Charitable Donations section

 

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

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