CSA Publications (CFR)

Joint CSA/CIRO Staff Notice 31-368 Client Focused Reforms: Review of Registrants’ Know Your Client, Know Your Product and Suitability Determination Practices and Additional Guidance

Staff Notice 31-368 outlines notable observations from a second phase of reviews of registrants’ compliance with the Client Focused Reforms. The Notice also sets out guidance to help registrants implement efficient and customized processes, while further aligning their practices with the requirements under the CFRs.

The Staff Notice 31-368 is available here.

A new CSA/CIRO Notice on the Know your client, Know your product and Suitability determination requirements under the Client Focused Reforms provides additional guidance for registrants on how best to ensure compliance.

Know Your Client:

  • Rule: Registrants must collect and regularly update key information about their clients.
  • Guidance: Registrants should use professional judgement to ensure they have enough client details to make informed recommendations.

Know Your Product:

  • Rule: Registered firms must take reasonable steps to assess the key features of the securities they offer.
  • Guidance: A registered firm’s KYP assessment process should align with its business model and the types of securities offered to clients.

Suitability:

  • Rule: Before making any investment recommendation, a registrant must assess its suitability for the client based on the client’s KYC information and the KYP assessment, as well as consider concentration, liquidity, costs and alternatives, and must always put the client’s interest first.
  • Guidance: Suitability processes should be tailored to the firm’s business model and offerings.

CSA Notice 31-357 Blanket Orders/Class Orders in respect of Certain Client Focused Reforms Provisions of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations

CSA Notice 31-357 is available here.

For further reference, the Annex B to the CSA Notice of Amendment are available on the following websites of CSA jurisdictions:

  • Autorité des marchés financiers [French] [English]
  • Alberta Securities Commission [English] 
  • British Columbia Securities Commission [English] 
  • Financial and Consumer Services Commission (New Brunswick) [French] [English]
  • Nova Scotia Securities Commission [English]
  • Ontario Securities Commission [English] 
  • Financial and Consumer Affairs Authority of Saskatchewan [English]
  • Manitoba Securities Commission [English]

National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) and Companion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations (31-103CP)

  • Autorité des marchés financiers [French] [English]
  • Alberta Securities Commission [English]  
  • British Columbia Securities Commission [English] 
  • Financial and Consumer Services Commission (New Brunswick) [French] [English]
  • Nova Scotia Securities Commission [English]
  • Ontario Securities Commission [English]
  • Financial and Consumer Affairs Authority of Saskatchewan [English]
  • Manitoba Securities Commission [English]