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Key aspects of the firm–client relationship
kyc Covers the foundational relationship between a Registered Representative and their client, including cross-border considerations.
Key Rules
- ✓The client relationship model
- ✓Concepts of trust, agency and conflicts of interest
- ✓Procedures and requirements for working with clients residing in the United States, including snowbirds and other foreign jurisdictions as applicable
- ✓Considerations for changes in residence
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Importance and content required of KYC information
kyc Addresses the range of client information required to fulfill KYC obligations.
Key Rules
- ✓Financial circumstances: income, liquidity needs, financial assets, liabilities, net worth, whether the client is borrowing to invest
- ✓Personal circumstances
- ✓Investment knowledge
- ✓Risk profile
- ✓Investment objectives and needs
- ✓Investment constraints and restrictions including EDI, ESG and other personal preferences
- ✓Investment time horizon
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Processes for assessing a client's risk profile
kyc Covers thorough assessment of a client's risk tolerance, capacity and need.
Key Rules
- ✓The client's willingness to accept risk or risk tolerance, including behavioural aspects
- ✓The client's ability to endure financial loss or risk capacity
- ✓How much risk is needed to achieve the client's goals or risk need
- ✓Resolving conflicts between a client's expectations and risk profile
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Types of business structures and investment opportunities
kyc Covers different business structures and how they impact investment opportunities.
Key Rules
- ✓Sole proprietorship
- ✓Partnership
- ✓Corporation (private vs. public)
- ✓Co-operative
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Documenting discussions with clients
kyc Addresses the need to accurately document client discussions and have clients confirm accuracy.
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Trusted contact person requirements
kyc Covers application of trusted contact person requirements to specific scenarios.
Key Rules
- ✓How to establish a trusted contact person
- ✓What this permits and what it does not permit
- ✓Actions if the client refuses to provide a trusted contact person
- ✓When to contact a trusted contact person
- ✓How to recognize potential capacity concerns
- ✓How to recognize financial exploitation issues
- ✓Conditions for using temporary holds
- ✓Document the discussion
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Primary responsibility and keeping KYC current
kyc Covers primary responsibility, prohibition on KYC delegation and the obligation to keep KYC current.
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Types of client account records and information collected
kyc Covers the types of client account records and information gathered.
Key Rules
- ✓Verification of identity
- ✓Account appropriateness assessment
- ✓KYC information
- ✓Acknowledgement of disclosures
- ✓Record of trusted contact person refusal
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Account appropriateness obligation
kyc Covers application of the account appropriateness obligation to specific scenarios.
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Key features of various types of accounts
kyc Covers matching account features, advantages and disadvantages to client requirements.
Key Rules
- ✓Advisory (non-managed) account – fee-based and commission-based
- ✓Managed account
- ✓Discretionary account
- ✓Cash account vs. margin account
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Account-related documentation and information collected
kyc Covers documentation related to account opening and information collected.
Key Rules
- ✓Investment Dealer's business model
- ✓Relationship with clients
- ✓Investment products and services offered by the Investment Dealer
- ✓Conditions for when to collect one set of KYC information for multiple accounts
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Objective and content of the Relationship Disclosure document
regenv Covers the purpose and required elements of the Relationship Disclosure document.
Key Rules
- ✓Objective
- ✓Frequency of provision
- ✓Form and format
- ✓Content
- ✓Review
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Containment of confidential information
ethics Covers the importance of protecting confidential information within an Investment Dealer.
Key Rules
- ✓Information barriers and firewalls
- ✓Grey and restricted lists
- ✓The role of investment banking, the research department and corporate finance
- ✓Cybersecurity
- ✓Privacy
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Required documents in the Investment Dealer's Welcome Package
regenv Covers the purpose of documents provided to clients in the Welcome Package.
Key Rules
- ✓Fee schedule
- ✓CIRO brochures (CIRO Complaints Brochure, How CIRO protects investors, Opening an Investment Account)
- ✓Canadian Investor Protection Fund
- ✓Derivative Risk Disclosure
- ✓Investment Dealer conflict of interest disclosures
- ✓Investment Dealer complaint handling procedures
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Product due diligence obligation
kyc Covers the product due diligence obligation on the Dealer and the Approved Person.
Key Rules
- ✓The Investment Dealer
- ✓The Approved Person
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Know-Your-Product (KYP) obligation
products Covers application of the KYP obligation to all investments purchased, sold or recommended.
Key Rules
- ✓Structure
- ✓Features (initial and ongoing costs)
- ✓Risks (impact of costs)
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Retail client suitability determination requirements
kyc Covers application of suitability determination requirements to specific situations.
Key Rules
- ✓The relationship of KYC to recommendations
- ✓The need to avoid excessive switches (churning)
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Unsolicited or unsuitable client instructions
kyc Covers obligations where client instructions are unsolicited or unsuitable.
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Types of investment action for a client's account
kyc Covers applying types of investment action to specific situations.
Key Rules
- ✓Purchasing
- ✓Selling
- ✓Holding a position
- ✓Depositing
- ✓Exchanging or transferring securities
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Account appropriateness vs. suitability determination
kyc Covers the difference between account appropriateness and suitability determination.
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Monitoring and maintaining accounts
kyc Covers Dealer and regulatory requirements for monitoring and maintaining accounts, including triggering events.
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Impact of changes on suitability determination
kyc Covers analysis of how relevant changes affect suitability for a client's portfolio.
Key Rules
- ✓Material change to the client's circumstances
- ✓Product and market research
- ✓Economic, political and social events
- ✓Emerging issues, financial trends, economic trends and world news
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Managing conflicts of interest in the client's best interest
ethics Covers regulatory requirements for managing conflicts of interest.
Key Rules
- ✓Identifying
- ✓Avoiding
- ✓Addressing
- ✓Disclosure
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Requirements relating to outside activities
ethics Covers requirements relating to outside activities in specific situations.
Key Rules
- ✓Definition
- ✓Pre-approval
- ✓Disclosure
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Personal financial dealings with clients
ethics Covers requirements relating to personal financial dealings with clients.
Key Rules
- ✓Prohibition and action relating to accepting consideration, settlement agreements, borrowing/lending, control or authority, comingling of assets
- ✓Business partnerships
- ✓Investment clubs
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Dealer policies for managing conflicts of interest
ethics Covers application of Dealer policies and procedures for managing conflicts of interest.
Key Rules
- ✓Effective controls and qualified supervision
- ✓Applicable due diligence process for approvals
- ✓Appropriate record-keeping
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CIRO standards of conduct
ethics Covers application of CIRO standards of conduct to situations involving representatives, clients and firms.
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Thorough processes for assessing a client's risk profile
kyc Examines how to assess a client's risk profile through willingness, ability and need for risk.
Key Rules
- ✓The client's willingness to accept risk or risk tolerance, including behavioural aspects
- ✓The client's ability to endure financial loss or risk capacity
- ✓How much risk is needed to achieve the client's goals or risk need
- ✓Resolving conflicts between a client's expectations and risk profile
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Types of business structures and impact on investment opportunities
kyc Covers different business structures and how they affect investment opportunities.
Key Rules
- ✓Sole proprietorship
- ✓Partnership
- ✓Corporation (private vs. public)
- ✓Co-operative
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Requirements around a trusted contact person
kyc Applies trusted contact person requirements to scenarios, including establishment, permissions and use.
Key Rules
- ✓How to establish a trusted contact person
- ✓What this permits and what it does not permit
- ✓Actions if the client refuses to provide a trusted contact person
- ✓When to contact a trusted contact person
- ✓How to recognize potential capacity concerns
- ✓How to recognize financial exploitation issues
- ✓Conditions for using temporary holds
- ✓Document the discussion
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Primary responsibility and KYC currency obligations
kyc Covers the prohibition on KYC delegation and obligation to keep KYC information current.
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Account appropriateness obligation applied to scenarios
kyc Applies the account appropriateness obligation to specific situations.
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Key features of various account types
kyc Applies advantages and disadvantages of account types to client requirements.
Key Rules
- ✓Advisory (non-managed) account – fee-based and commission-based
- ✓Managed account
- ✓Discretionary account
- ✓Cash account vs. margin account
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Account-related documentation and opening process
kyc Covers documentation tied to account opening and the information collected relative to the dealer's model.
Key Rules
- ✓Investment Dealer's business model
- ✓Relationship with clients
- ✓Investment products and services offered by the Investment Dealer
- ✓Conditions for when to collect one set of KYC information for multiple accounts
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Required documents in the Welcome Package
regenv Covers the purpose of documents included in the Investment Dealer's Welcome Package.
Key Rules
- ✓Fee schedule
- ✓CIRO brochures (Complaints Brochure, How CIRO protects investors, Opening an Investment Account)
- ✓Canadian Investor Protection Fund
- ✓Derivative Risk Disclosure
- ✓Investment Dealer conflict of interest disclosures
- ✓Investment Dealer complaint handling procedures
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Obligations for unsolicited or unsuitable instructions
kyc Covers obligations of the Registered Representative and Dealer when instructions are unsolicited or unsuitable.
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Monitoring and maintaining accounts requirements
kyc Analyzes Dealer and regulatory requirements for monitoring accounts and triggering events.
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Managing conflicts of interest in client's best interests
ethics Applies regulatory requirements for managing conflicts of interest to specific situations.
Key Rules
- ✓Identifying
- ✓Avoiding
- ✓Addressing
- ✓Disclosure
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CIRO standards of conduct applied to situations
ethics Applies CIRO standards of conduct to situations involving a Registered Representative and their client or firm.