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ARTICLE · 26 OCTOBER 2023

OSFI's Draft Security And Integrity Guideline: What's Expected Of FRFIs And When?

Stikeman Elliott LLP
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On October 13, 2023, OSFI released its draft Integrity and Security Guideline ("Guideline"). The Guideline, which would layer new and expanded expectations over existing applicable guidance...

CanadaEmployment and HR
Andrew Cunningham
Andrew Cunningham
Stuart Carruthers
Stuart Carruthers
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On October 13, 2023, OSFI released its draft Integrity and Security Guideline ("Guideline"). The Guideline, which would layer new and expanded expectations over existing applicable guidance, would apply to all Federally Regulated Financial Institutions ("FRFIs"), including foreign bank and insurance company branches in relation to their Canadian business.

The consultation period is short, with responses due by November 24, 2023. OSFI will issue the final Guideline by January 31, 2024.

Background

The Guideline follows amendments to FRFI statutes in Bill C-47, the Budget Implementation Act, which received Royal Assent on June 22, 2023. In effect as of January 1, 2024, the amendments extend OSFI's mandate to include the supervision of FRFIs to determine whether they have established policies and procedures adequate to protect against threats to integrity and security, including foreign interference. Among other things, this requires OSFI to assess FRFIs with

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