THE 360 NEWSLETTER

Since the launch of our remote account opening procedure in 2020 (ref. March 26, 2020 360 communication), we have received a number of questions and feedback regarding this process. For this reason, we are taking this opportunity to provide a few important reminders below.

Additionally, in order to clarify its use with your clients, we have renamed Administrative Procedure # 58 from Remote Account Opening to Remote New Client Identification (Account Opening).

Important Reminders:

When to Use It

This procedure can be used when you need to identify a new client remotely (or the authorized signatories in the case of entities) and to open an account in a compliant and secure manner via the Investia Client Portal and the Electronic Signature Tool, without having to meet the client in person or obtain his or her wet signature.

Document Sharing

The “Document Sharing” feature of the Client Portal was created to allow your clients to easily and securely share documents with you in compliance with the FINTRAC requirement for dual identification is met.

Electronic Signature Tool

Once your client has been identified, the E-Signature Tool can then be used by Representatives as a secure and efficient method to open an account in keeping with our regulatory requirements. Note that this tool is the only acceptable tool for all Investia-related business and is to be used in conjunction with the Client Portal.

Note also that the Investia Electronic Signature Tool cannot be used for any of your outside activities. For these activities, a different solution must be used, keeping in mind that it should respect the applicable integrity and security requirements.

Below is a list of common deficiencies we see with this process:

• A note indicating that the client was identified remotely has not been added as it should in Univeris at the client level or on the NCAF form. Here is an example of an acceptable note:

“The method used for identification is the dual source method. A virtual meeting was held on [date] at [time]. The documentation was sent to imaging.”

• All supporting documentation is not sent to imaging for dealer records when the new account opening is processed in Univeris.
• Illegible copies of supporting documents/information appear in imaging (documents need to be scanned in grayscale for greater clarity).
• Each account owner or authorized financial person has not been identified as per the procedure. If the individual is an existing client who is opening a new account ownership creating a new client ID, please indicate the client’s Univeris ID on the form for compliance supervisor review and consider linking the clients to this new client ID.

For more detailed information, we invite you to read the amended Administrative Procedure – 58 Remote New Client Identification (Account Opening), available on the Advisor Centre under Procedures and Forms / Administrative Procedures.