THE 360 NEWSLETTER

Vulnerable Clients – Useful Resources

Compliance July 6, 2023

With the aging population giving way to more clients with diminished capacities and other vulnerabilities, is it important to be alert and properly equipped to be able to detect signs of potential abuse and provide adequate resources.

In this spirit, Québec’s Autorité des marchés financiers (AMF) and the Canadian Investment Regulatory Organization (CIRO) each published a guide which provides useful tips to complement your business:

Protecting vulnerable clients – A practical guide for the financial services industry (lautorite.qc.ca) (updated guide)

Seniors’ Month Investment Tips (ciro.ca)

Below are a few reminders of some good practices to adopt:

  • Have a trusted contact person on file for your clients (other than the power of attorney (POA);
  • Have an up-to-date power of attorney/mandate on file in case of incapacity;
  • Never hesitate to discuss with your client, when possible, even if the instructions come from the POA;
  • The POA cannot name or change beneficiaries;
  • The POA cannot change the registration of the account (e.g., from individual to joint); and
  • All transactions must be carried out in the client’s best interest, not the POA’s or the beneficiaries’!

Investia’s policies and procedures are constantly evolving and adapted to face this reality. For additional information, we invite you to read Chapter 4, Section IV. F) Vulnerable Clients of Investia’s Compliance Policies and Procedures Manual.

Should you encounter a situation where you need more guidance with vulnerable clients, please do not hesitate to contact your Compliance Officer.