August 28, C-106

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1 August 28, C-106 QUESTIONS ANSWERS A. Transactions prior to September 1, 1996 All mutual fund transactions that were off-book as defined in IDA Compliance Interpretation Bulletin C-93 prior to September 1, 1996, for which Member firms registered representatives accommodated client mutual fund transactions directly between the mutual fund company and their clients without opening an account at the Member firm. i) Are Member firms required to reconstruct and maintain historical mutual fund security position records for trades prior to September 1, 1996? For Contractual {pre-authorized chequing (PAC)/automatic withdrawal (AWD)} Plans set up prior to September 1, 1996 where clients purchase or redeem set amounts of mutual funds on a regular or predetermined basis and the cash is drawn directly by the Fund Company from the client s bank account or forward to the client s bank account from the fund company: i) Are Member firms required to open an account? ii) Are Member firms required to record transactions for this plan? iii) Are Member firms required to maintain a mutual fund security position For mutual fund purchases after September 1, 1996 in n-contractual (regular investment accounts or client self-directed registered retirement savings plans (RRSP) held at a fund company) accounts that exist prior to September 1, 1996: i) Are Member firms required to open an account for the client on their (Cash books? accounts) ii) Are Member firms required to record mutual fund transactions in this account? iii) Are Member firms required to maintain a mutual fund security position * t applicable as off-book mutual fund transactions were in client name only.

2 August 28, C-106 B. Purchases on or after September 1, All Member firms are required by SRO rules and Provincial Securities Acts to: Open client accounts; a) Contractual Plans opened on or after September 1, 1996: i) Can cash be sent directly to the Fund Company from the client s bank, however, the, however, the account? first transaction first transaction must be booked must be booked by the Member by the Member firm. firm. ii) Are Member firms required to open an account on their records? iii) Are Member firms required to record any transactions?, for the first transaction. iv) Are Member firms required to send trade confirmations and account, for the first, for the first statements to each client? transaction and transaction. thereafter written summaries of trades every six months. v) Are Member firms required to maintain a security position b) n-contractual Purchases on or after September 1, 1996: i) Can cash be sent directly to the Fund Company from the client s bank account? ii) Are Member firms required to open an account on their records? iii) Are Member firms required to record any transactions? iv) Are Member firms required to send out trade confirmations and account statements to clients? v) Are Member firms required to maintain a mutual fund security position

3 August 28, C-106 C. GROUP RRSP Self-Directed Group RRSP s at the Fund Company are held in client name only and may be in contractual or non-contractual form. All Member firms are required by SRO rules and Provincial Securities Acts to: Open cash account for each participant; For contractual group RRSP plans, please refer to Section B, Part a). For non-contractual group RRSP plans, please refer to Section B, Part b). D. Redemptions For redemptions of mutual fund units held in regular Investment accounts or client requests to set up automatic withdrawal plans: i) Are Member firms required to record any transactions?, security position does not exist on the books of the Member. ii) Are Member firms required to send trade confirmations and account statements to client? iii) Are Member firms required to maintain a security position

4 August 28, C-106 E. Client self-directed RRSP Transfers For client self-directed RRSP transfers where the authorization to transfer the account is duly executed by the client, all Member firms are required by SRO rules and Provincial Securities Acts to: Open client accounts; a) Dealer to dealer transfer of client self-directed RRSP. Account held at the fund company, where the only change involved is the dealer/member firm code and the registered representative code. i) Are Member firms required to open an account on their books? ii) iii) iv) Are Member firms required to record the transfer on their books? Are Member firms required to record subsequent transactions? Are Member firms required to send trade confirmations and account statements to clients for subsequent transactions? v) Are Member firms required to maintain a mutual fund security position b) Transfer of a client self-directed RRSP at a financial institution to a client self-directed RRSP at a fund company on the advice of a Member firm s registered representatives. For example, cash from a maturing registered product (Term Deposit/GIC) in a client self-directed RRSP account at the financial institution to mutual fund units in a client self-directed RRSP account at the fund company. i) Are Member firms required to open an account on their records? ii) iii) iv) Are Member firms required to record the transfer? Are Member firms required to record subsequent transactions? Are Member firms required to send trade confirmations and account statements to clients for subsequent transactions? v) Are Member firms required to maintain a mutual fund security position, cash account., cash account * t applicable because client self-directed RRSP accounts are in client name only.

5 August 28, C-106 F. Switch transaction For switch transaction which comprises a redemption and a purchase within the same client account and the same fund company involving any combination of equity, money market and next day pricing funds. All Member firms are required by SRO rules and Provincial Securities Acts to: i) Are Member firms required to record any transactions?, security position does not exist on the books of the Member.* ii) Are Member firms required to send trade confirmations and account statements to client? iii) Are Member firms required to maintain a mutual fund security position G. General Is the filing for exemptions to the Provincial Securities Commissions on hold? Are Member firms required to send trade confirmations for dividend reinvestments?, pending decision from CSA on this matter., dividend reinvestment is an entitlement not a purchase. *However all Member firms must maintain Know Your Client information to ensure the suitability of the purchase side of the switch transaction.

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