THE 360 NEWSLETTER

As part of our efforts  to promote continuous improvement and business process efficiency, please review the following common deficiencies to keep in mind when reviewing client information and portfolios. The guidance and tips below will assist you in receiving fewer inquiries from your Compliance Supervisor. Most of these reminders are based on the Client-Focused Reform (“CFR”) regulatory requirements or enhanced obligations from other jurisdictions.

Liquidity Needs

Please ensure that the liquidity needs question is answered either “Yes” or “No” as part of your NCAF/KYC Update Form completion process. This mandatory section is used to determine whether the client expects to use their Investia account assets to cover ongoing and short-term expenses.

Intended Use of Accounts or Investments

The intended use of investments or an account is one of the factors that help determine the client’s possible time horizon, risk profile and asset allocation/objectives. As such, it is material to the client’s KYC information.

Trusted Contact Person

• To reiterate, under CFR obligations, Representatives must take reasonable steps to obtain from the client the name of a trusted contact person (“TCP”) they would like to disclose to the Representative and dealer, as well as the TCP’s relationship to the client, telephone and/or email, which must be documented for our records. Or, if the TCP is an existing client of Investia, the client’s Univeris client ID and relationship to the client may be inserted in the TCP section.
• Having a TCP on file may be of particular importance in the event of a situation of vulnerability or if a concern is raised about the client’s ability to understand recommendations provided by his/her Representative. For more information, please refer to the 360 communication from July 6, 2023 (Vulnerable Clients – Useful Resources).

FATCA/CRS

• As per the 360 communication from November 24, 2022 (Foreign Tax Reporting Requirements (FATCA/CRS) – Consequences of Non-Compliance Effective January 1, 2023), please ensure that the FATCA/CRS question is answered on the NCAF/KYC Update Form for individual and joint clients.
• For entities, please ensure that the Investia Complementary Form – Corporation, Formal Trust and Other Entities (F51-286A) (“complementary form”) is completed in full.
• Where a Confirmation of Identity – Related Parties form (F51-376A) or complementary form (F51-286A) was completed prior to June 30, 2017, the Investia complementary form or the government Declaration of Tax Residence for Entities form (RC519) must be completed again because the Common Reporting Standard (“CRS”) came into effect that date.

For additional information regarding liquidity needs, the intended use of investments/accounts and trusted contact persons, we encourage everyone to review the Client-Focused Reform (“CFR”) Training – Module 3 – Know-Your-Client (KYC and Other Requirements on Investia Learning. This training qualifies for one (1) PDU in Compliance (CO) from the Chambre de la sécurité financière (“CSF”), as well as one (1) CE credit in Business Conduct (BC) from the Canadian Investment Regulatory Organization.

Should you have any questions regarding this memo, please do not hesitate to contact your Compliance Supervisor.