The Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) have issued Joint CSA/CIRO Staff Notice 31-368 setting out findings from a second phase of reviews of registrants’ compliance with Client Focused Reforms requirements on know your client (KYC), know your product (KYP) and suitability determinations, alongside additional guidance for firms. The review found that many firms made efforts to update processes to reflect the enhanced requirements, but some did not update their processes fully and were required to address identified compliance issues. The sweep covered 105 firms, including investment fund managers, portfolio managers, restricted portfolio managers, exempt market dealers, investment dealers and mutual fund dealers. The notice highlights notable observations, provides examples of compliance issues identified through the reviews, and offers guidance intended to help registrants implement efficient, customized processes that better align with the CFR requirements. This work follows earlier CSA/CIRO reviews and guidance focused on conflicts of interest practices under the reforms.
Canadian Securities Administrators 2025-12-10
Canadian Securities Administrators and Canadian Investment Regulatory Organization publish findings and guidance from Client Focused Reforms Phase 2 compliance sweep
The Canadian Securities Administrators and the Canadian Investment Regulatory Organization issued Joint Staff Notice 31-368, detailing findings from a review of 105 firms' compliance with Client Focused Reforms on know your client, know your product, and suitability determinations. While many firms updated their processes, some did not fully comply and must address issues. The notice provides observations, examples of compliance issues, and guidance to help firms align with the reforms.