As we approach the end of the second quarter, it is a good time
for registered firms to reflect on whether they have completed
appropriate training for employees. Under National Instrument
31-103 Registration Requirements, Exemptions and Ongoing
Registrant Obligations (NI
31-103), firms are expected to provide
training on specific topics. At a minimum, firms must provide
training on conflicts of interest (COI), know your
client (KYC), know your product
(KYP) and suitability determination obligations
during the year. As noted in our article above regarding the
BCSC's annual Compliance Report Card for 2022, COI was one of
the top areas where the most deficiencies were found. The BCSC and
other securities regulators can impose significant administrative
penalties for contraventions. The Ontario Securities Commission has
also signaled in recent annual reports and in their Statement of
Priorities for 2023 that COIs are high on staff's radar.