The next phase of CRM2 is around the corner! We recommend that you speak with us to ensure that your compliance systems observe the new rules well in advance of the December 31, 2015 deadline. Your client statements relating to the period ending on December 31, 2015 must include the following new items of disclosure:

  • securities subject to a deferred sales charge
  • if applicable, the name of the securities’ custodian and a description of the way they are held
  • position cost information for each security and a total for all securities in the account, for which you must choose between providing either book cost or original cost information (if neither is available, you have certain options you can consider)
  • the market value for securities held in the account – calculated as of the last net asset value for investment funds, and the last bid or ask price for publicly traded securities; in the case of private or illiquid securities, you can estimate the value or list their value as “not determinable”

Regarding the requirement that client statements disclose the securities covered by an investment protection fund, CSA Staff Notice Notice 31-341 states:

The requirement to identify securities that may be covered under an investor protection fund in their additional statements does not have to be met (we plan to publish a proposal to amend this requirement at a later date). IIROC's existing investor protection fund disclosure requirements remain in effect. The MFDA has introduced equivalent requirements that will come into effect as of December 31, 2015.