The Investment Industry Regulatory Organization of Canada has reconfirmed its continued view that dealer members may use part-time chief financial officers. Under IIROC rules, every dealer member must have a CFO, and the CFO must be a partner, director or other “executive” officer of the firm. According to IIROC, the regulatory obligations of a part-time CFO are precisely the same as a full-time CFO and “[t]he duties and responsibilities of the CFO are not attenuated if the CFO works off-site or if the CFO works with a number of Dealer Members.” IIROC cautions that “[a] Dealer Member engaging a part-time CFO (including a CFO who routinely works off-site or with another Dealer Member) should continually evaluate the growth and development of the business and consider whether a part-time CFO continues to be appropriate for the scale and scope of the business activities being undertaken.” In Canada, a dealer is what would constitute a broker or a dealer in the United States.
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