Portfolio Managers Association of Canada Regulatory Update April 17, 2014
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1 Portfolio Managers Association of Canada Regulatory Update April 17, 2014 Chris Jepson, Ontario Securities Commission Kate Holzschuh, British Columbia Securities Commission Martha Kane, British Columbia Securities Commission
2 Disclaimer The presentation is provided for general information purposes only and does not constitute legal or accounting advice. Information has been summarized and paraphrased for presentation purposes and the examples have been provided for illustration purposes only. Information in this presentation reflects securities legislation and other relevant standards that are in effect as of the date of the presentation. The contents of this presentation should not be modified without the express written permission of the presenters.
3 Presentation outline Client Relationship Model, Phase 2 Dispute resolution service KYC and suitability obligations Local initiatives
4 Client Relationship Model, Phase 2 Amendments to National Instrument Registration Requirements, Exemptions and Ongoing Registrant Obligations Cost and performance reporting, client statement requirements Planning and implementation
5 Transition COST DISCLOSURE Pre-trade disclosure of charges Trade confirmation - debt securities Trade confirmation - deferred sales charges Report on charges and other compensation PERFORMANCE REPORTING Investment performance report ACCOUNT STATEMENT / ADDITIONAL STATEMENT New account statement / additional statement Position cost information IFM DUTY TO PROVIDE INFORMATION 5
6 CRM2 Frequently Asked Questions Introduction/comments
7 Relationship Disclosure Information Must deliver to all clients that are individuals, including permitted clients Any questions?
8 Account / Additional Statements A note on the terminology Delivery frequency Legacy securities in an account Reliance on third-party custodians Any questions?
9 Report on charges & compensation First reporting period First day of reporting period Last day of reporting period (year-end) August 1, 2015 July 31, 2016 September 1, 2015 August 31, 2016 October 1, 2015 September 30, 2016 November 1, 2015 October 31, 2016 December 1, 2015 November 30, 2016 January 1, 2016 December 31, 2016 February 1, 2016 January 31, 2017 March 1, 2016 February 28, 2017 April 1, 2016 March 31, 2017 May 1, 2016 April 30, 2017 June 1, 2016 May 31, 2017 July 1, 2016 June 30, 2017
10 Report on charges & compensation cont d Fund management fees End of relationship Referral fees Any questions?
11 Report on investment performance Frequency of reports Legacy data Any questions?
12 Questions?
13 Dispute resolution service Ombudsman for Banking Services and Investments (OBSI) to be the common, independent DRS for the securities industry Introduction/comments
14 Ombudsman for Banking Services and Investments (OBSI)
15 Amendments to NI Registration Requirements, Exemptions and Ongoing Registrant Obligations and Companion Policy Effective May 1, 2014 Regarding the provision of dispute resolution services Outside Québec, a firm must take reasonable steps to ensure that the Ombudsman for Banking Services and Investments (OBSI) will be the dispute resolution service that is made available to a client that has an eligible complaint. Requirement to inform clients in writing about the firm s obligation and to set out the steps a client must take in order to be able to access OBSI.
16 Purpose All registered dealers and registered advisors are to use OBSI as the dispute resolution service to provide investors with: access to a free, independent, consistent dispute resolution service, uniform handling of investor complaints for all types of advisors, and clarity on who investors should contact if complaints are not resolved by the advisor. As members of a self-regulatory organization (SRO), MFDA and IIROC firms are already obligated to offer OBSI.
17 Quebec The Autorité des marchés financiers (the AMF) already provides a mediation service to clients residing in Québec. The Québec regime will remain unchanged and firms registered in Québec should continue to inform clients residing in Québec of the availability of the AMF mediation services.
18 OBSI Eligible Complaints Complaints related to trading or advising of the firm or its representative; If raised within 6 years of the date when the client knew or reasonably ought to have known of the act or omission that is a cause of or contributed to the complaint; Claims not exceeding $350,000; Does not apply to a permitted client that is not an individual.
19 Client Disclosure Required at three points in time: Account opening;** Time of complaint; Time of decision. **for existing clients, firms will need to update their Relationship Disclosure Information.
20 Disclosure- at account opening Firms must provide written disclose of: the firm s obligations if a client has a complaint; the steps the client must take in order for OBSI to be made available at the firm s expense. Disclosure can be included in: a single document (together with other required relationship disclosure information); or in a separate document. Avoid the use of technical terms and acronyms when communicating with clients.
21 Disclosure- time of complaint Firms must provide the client with a written acknowledgement of the complaint, typically within 5 business days. Must include: information about the firm s complaint process, including timelines for responding to client complaints; when and how to take their complaint to OBSI; contact information for OBSI; and, other options available to the client to resolve their complaint. May include: Request for additional information; Decision if available.
22 Disclosure- time of Decision Firms are expected to provide a decision within 90 days of receipt of the complaint. If rejecting a complaint or making an offer, the firm must provide the client with written notice of: the decision, and information about OBSI, including: o timelines applicable for using OBSI, o monetary limits associated with OBSI, and, o contact information for those services. As a best practice, a firm should also include: a summary of the complaint, and reasons for the firm's decision.
23 If Decision is Delayed If firm cannot provide a decision within 90 days, they should: inform the client of the delay, explain why the decision is delayed, and give a new date for your decision. Remind the client they have the option to access services of OBSI after 90 days. Note: Whether a decision is delivered or not, the client has the option to access services of OBSI after 90 days.
24 To Provide Guidance CSA developing guidance to publish in conjunction with the new requirements coming into effect that will: summarize the requirements; provide some best practices; provide a sample disclosure developed to fulfill obligations.
25 Best Practice: Disclosure Embed the disclosure in the body of the firm s acknowledgement and decision letters, or reference in the letters that it is being included. Why? to assist the firm with providing evidence that you fulfilled your obligation for client disclosure, and may protect the firm in the event a client later claims they did not receive information about independent dispute resolution servicesparticularly the 180 day timeline for accessing OBSI.
26 Accessing OBSI A client may access OBSI: after 90 days of the firm receiving the complaint, whether or not the firm has sent the client written notice of a decision; if the client notifies OBSI that it wants to use their services within 180 days of receiving the firm s written decision.
27 Other Options for Clients Firms should not make another dispute resolution service available; Firms are only required to make one service available at its expense; that being the OBSI; Where a client declines OBSI services, there is no obligation to offer an alternative at firm s expense; Client may decide to use other dispute resolution services, at their own expense; Clients always have the right to go to a lawyer or seek other ways of resolving their dispute at any time.
28 Updating Relationship Disclosure Information (RDI) Firms are required to take reasonable steps to notify clients, in a timely manner, of significant changes in respect of the relationship disclosure information. The changes regarding offering OBSI are considered a significant change therefore firms expected to update clients. Options: send update separately, or with an upcoming client communication, i.e. next monthly or quarterly statement, or before next transaction.
29 Membership in OBSI Firms are expected to: attain, and maintain, membership in OBSI as a Participating Firm. deal fairly, honestly and in good faith with its clients. Cooperate with the investigation process. For more information on how to register as a Participating Firm, visit
30 Transition Period Three months transition for firms registered before May 1, 2014 Applies to all complaints received after August 1, 2014 No transition period for new firms registered after May 1, 2014.
31 From a CCO s Perspective- OBSI OBSI processes have evolved; OBSI has experience with managed money complaints/will continue to gain experience; OBSI has a well defined investigation process with several layers of review. In the event, you have an issue with the investigation or the investigator there are avenues to discuss this with more senior people.
32 From a CCO Perspective- Firms Have a consistent adviser discovery/kyc process that includes fulsome notes to reference later; Be engaged in the OBSI investigation process; Give feedback to PMAC; Have an effective complaint and investigation process.
33 Questions?
34 KYC and Suitability Published January 9, 2012: CSA Staff Notice Guidance for Portfolio Managers, Exempt Market Dealers and Other Registrants on the Know-Your-Client, Know-Your-Product and Suitability Obligations
35 Regulatory framework National Instrument Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI ) Principal KYC, KYP and suitability obligations o o Section 3.4 Proficiency (KYP) Part 13, Division 1 KYC & suitability
36 Overview of KYC obligation Basic KYC obligation for registrants requires registrant to take reasonable steps to establish identity (and reputation) of client establish whether client is an insider ensure registrant has sufficient information to meet suitability obligation establish creditworthiness if margin account Additional requirements if client is a corporation, partnership or trust corporation person who owns or controls more than 25% of voting securities partnership or trust person who exercises control
37 Obligation to know client s essential facts Requires registrant to know client s investment needs and objectives financial circumstances risk tolerance for various types of securities and investment portfolios Obligation to take reasonable steps to keep information current
38 Why is KYC important? Section 13.2 of the Companion Policy to NI (CP ): Registrants act as gatekeepers of the integrity of the capital markets. They should not, by act or omission, facilitate conduct that brings the market into disrepute. As part of their gatekeeper role, registrants are required to establish the identity of, and conduct due diligence on, their clients under the [KYC] obligation KYC information forms the basis for determining whether trades in securities are suitable for investors. This helps protect the client, the registrant and the integrity of the capital markets.
39 When does KYC apply? A registrant is required to make a suitability determination before a registrant makes a recommendation to or accepts an instruction from a client to buy or sell a security, or purchases or sells a security for a client s managed account Registrants are required to make reasonable efforts to keep KYC info current
40 KYC Guidance Get to really know-your-client engage in meaningful discussions with clients (e.g. use of questionnaire) develop an investor-friendly KYC form (define KYC terms like risk tolerance, investment objectives in plain language) consider a client s willingness vs ability to accept risk review the KYC information to ensure completeness and accuracy
41 KYC Guidance Review the KYC information with the client to ensure accuracy Sign and date the KYC information (both the client and the registrant)
42 KYC updating KYC information must be current when assessing suitability of investment Update KYC information at least annually or more often if there is a material change in client s circumstances (e.g. marriage, birth of a child, loss or change in employment, etc.) Updated KYC information should be signed by the client and the registrant
43 KYC includes determining AI status If a registrant proposes to make a trade in reliance on the accredited investor (AI) exemption in NI Prospectus and Registration Requirements (NI ), the registrant is required to determine whether the client is an AI For additional guidance, see Section 1.9 [Responsibility for compliance] and subsection 3.5(6) [Time for assessing qualification] of the Companion Policy to NI (CP ) Section 3.3 [Responsibility for compliance] of the Companion Policy to OSC Rule Ontario Prospectus and Registration Exemptions (CP ) OSC Staff Notice Sale of Exempt Securities to Non-Accredited Investors (OSC Staff Notice )
44 Examples of unacceptable practices KYC information Delegate the KYC obligation to an unregistered individual Collect KYC information solely by asking a client to tick a box that best describes their investment objectives or risk tolerance Process a trade with missing or conflicting KYC information Use outdated KYC information to assess suitability of investment Use a KYC form or other document that contains inappropriate disclaimer language
45 What is the KYP obligation? Registrants should know each security well enough to understand and explain to their clients the security s risks, key features, and initial and ongoing costs and fees Products sold under a prospectus exemption may require a more extensive review because of the limited disclosure available about them Sawh and Trkulja (2012) See CSA Staff Notice Suitability Obligations and Know-Your-Product dated September 2, 2009
46 KYP Guidiance Must conduct own product due diligence and be able to explain to clients about the security s risk, key features, and initial and ongoing cost and fees Consider additional risks such as liquidity risk, valuation risk, and conflict of interest risk (particularly if you are distributing a product of a related or connected issuer) Conduct further due diligence if the offering memorandum or offering documents do not contain sufficient information Do not solely rely on third-party analysis and reports prepared by unregistered third parties For additional guidance, see CSA staff notice Suitability Obligations and Know-Your-Product
47 Examples of unacceptable practices KYP Fail to fully understand the structure and features of the products and recommend the product solely based on information from issuers or other third parties Rely solely on a product being on the firms approved product list without understanding the product features and risks
48 What is the suitability obligation? NI requires a registrant to take reasonable steps to ensure that, before it makes a recommendation to, or accepts an instruction from, a client to buy or sell a security, or makes a purchase or sale of a security for a client s managed account, the purchase or sale is suitable for the client As explained in CP , suitability obligations cannot be: delegated to a third party, satisfied simply by disclosing the risks of the trade, or waived (except by investors that are permitted clients as defined in NI ).
49 Why is suitability important? Suitability is a fundamental obligation owed by registrants to their clients and a cornerstone of our investor protection regime Staff expect firms to comply with both the letter and the spirit of these requirements This requires a meaningful suitability assessment, Appropriate documentation is essential
50 Suitability assessment Establish policies and procedures for assessing suitability of investment Consider all relevant KYC information Review each trade independently Develop a system to identify and reject trades that are inconsistent with client s investment needs and objectives Maintain adequate documentation of each trade and be able to demonstrate how each trade was assessed for suitability Establish a process to periodically review a sample of client files to ensure that the suitability process is applied consistently Provide adequate training
51 Questions?
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