THE 360 NEWSLETTER

KYP Obligation Reminders and Compliance Oversight

Compliance July 28, 2022

As you may be aware, the Know Your Product section of National Instrument 31-103, which came into effect on January 1, 2022, stipulates that Representatives must demonstrate that due diligence has been completed pre-trade for any product that they recommend to their clients. To facilitate this obligation, Investia has released the KYP tool, which can be found in the Dashboard on the Advisor Centre.

The KYP tool is designed to provide the Representative with a means to complete due diligence on products they are recommending to their clients. With the use of dealer determined peer groups, the KYP tool also provides a comparative lens to help assess funds based on their risk, rate of return and management expense ratio (MER).

To help you better meet KYP obligations for your book of business, we recommend that you focus on completing KYP due diligence on those funds that you are frequently recommending. It is recommended to complete KYP due diligence in the order of AUA. For example, start from funds with the highest AUA and work your way down the list.

Please note that due diligence can only be completed via the KYP tool for funds that the Representative has at least 1 holding in. For new funds to the Representative’s book, an independent review of the funds will need to be performed pre-trade and due diligence will need to be completed once the trade settles and the fund appears in the Representative’s fund listing within the KYP tool.

The Know Your Product Policy has been integrated into Chapter 5 of the Investia Compliance Policies and Procedures Manual (CPPM), which can be found on the Advisor Centre under Guides and Training / Compliance. KYP training for Representatives can be found by clicking on the Investia Learning tab on the Advisor Centre as per image below:

We ask that you continue to complete your KYP fund due diligence pre-trade (when applicable) to meet your KYP obligations. Over the next couple weeks, you may receive friendly reminders or inquiries regarding your KYP due diligence by your Compliance officer.

Should you have any questions or require additional information, please do not hesitate to contact your Compliance Officer.