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March 7, 2014
CRM2 FAQ published; planning tips
The Canadian Securities Administrators (CSA) has published Staff Notice 31-337 Cost Disclosure, Performance Reporting and Client Statements - Frequently Asked Questions and Additional Guidance as of February 27, 2014 (the FAQ).
You will be aware that amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and its Companion Policy implementing phase 2 of the client relationship model came into force on July 15, 2013 (the CRM2 Amendments).
The CRM2 Amendments form a common baseline applicable to all registered dealers and advisers, and they also have some application to investment fund managers. We expect requirements for members of the Investment Industry Regulatory Organization of Canada and members of the Mutual Fund Dealers Association of Canada to be materially harmonized and implemented on the same timetable.
In the FAQ, we have compiled a list of frequently asked questions about the CRM2 Amendments and provided our responses, along with additional guidance. Click the links above to read the FAQ and the CRM2 Amendments.
You will also be aware that the CRM2 Amendments are being implemented in stages, with new requirements coming into effect on July 15 in each of 2014, 2015 and 2016. We encourage you to plan now so that you will be ready at each stage.
The attached "CRM2 Planning Tips" document sets out some things we think firms should consider when planning for implementation of the CRM2 Amendments.