Do you work from home regularly? Do you meet clients or conduct dealing or advising activities from home? Do you maintain records at home that are not duplicated at your firm’s office? These are all questions to consider when addressing other business locations in your compliance policies and procedures.
The Investment Industry Regulatory Organization of Canada (IIROC) recently issued guidance to clarify their approach and expectations relating to work from home arrangements. NI 33-109 Registration Information defines “Business Location” as a location where the firm carries out an activity that requires registration, and includes a residence if regular and ongoing activity that requires registration is carried out from the residence or if records relating to an activity that requires registration are kept at the residence. The IIROC guidance sheds light on how other regulators may determine whether a residence should be reported as a Business Location and serves as a reminder to our clients that it is important to have appropriate compliance policies and procedures in place in place for other Business Locations.