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ARTICLE · 24 JANUARY 2014

CSA Issues Guidance On Know-Your-Client, Know-Your-Product And Suitability Obligations

On January 9, 2014, the Canadian Securities Administrators ("CSA") issued CSA Staff Notice 31-336 Guidance for Portfolio Managers, Exempt Market Dealers and Other Registrants on the Know-Your-Client, Know-Your-Product and Suitability Obligations (the "2014 Notice").

CanadaCorporate/Commercial Law

HIGHLIGHTS:

  • Establish policies and procedures for collection of KYC information, meaningful KYP and suitability assessment – provide adequate training to ensure understanding by representatives.
  • Take proactive steps to maintain current KYC information – beyond "tick the box".
  • Have an in-depth understanding of structure, risks, costs and parties involved with product.
  • Adequately document and periodically review KYC, KYP and suitability processes.
  • Adequately understand and appropriately use client-directed trade instructions.
  • Review "best practices" for self-assessment of compliance with regulatory obligations.

On January 9, 2014, the Canadian Securities Administrators ("CSA") issued CSA Staff Notice 31-336 Guidance for Portfolio Managers, Exempt Market Dealers and Other Registrants on the Know-Your-Client, Know-Your-Product and Suitability Obligations (the "2014 Notice"). CSA issued the 2014 Notice to assist

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