Moderator: Gary Legault, Legault Compliance Consulting
Annual ‘10 Ugly Questions’
Panelists:
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Cas Litwin
FundEX Investments Inc.
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Michael Smith
Credential Financial
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Som Houmphanh
Sentinel Financial Management Corp
How does Your Firm Handle...
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Point of Sale (POS)
Remote Supervision
of Branches
OBA disclosure
Fee Based Financial
Planning
Annual Compliance
Questionnaire
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Cookie Cutter KYC’s
Product Review
Reporting to the
Board of Directors
How do you present
your Disclosures
CRM2
POS – Point of Sale
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What’s your firm doing now?
What challenges are you facing?
What’s on the horizon?
Remote Supervision of Branches
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What supervision structures do you have in
place?
Are there limits on how many DRs can be
supervised by one person remotely?
What contact and visitation policies and
procedures are in place?
OBA Disclosure
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What OBA Activity must be disclosed
to you ?(commercial/non-commercial)
Do all OBAs require disclosure?
In reference to Insurance OBA, how
detailed must the disclosure be?
Fee Based Financial Planning
What’s your firm doing now and why?
What are the biggest challenges?
What do you see in the future for our industry?
Annual Compliance
Questionnaire
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Do you utilize one?
How many questions?
Is it mandatory and, if so, how is non compliance
handled?
How is it delivered and completed?
How is it reviewed?
Cookie Cutter KYC’s
Has your firm defined it?
What do your policies and procedures say about it?
How do you look for it in trading activity and/or
onsite reviews?
What do you do if you find it?
Product Review
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What is your process ?
How do you educate your advisors on new
product?
How is approved product made known to
advisors?
What is identified for advisors?
Can they do customized searches?
Reporting to the Board of Directors
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How frequently?
What is your reporting format?
What topics are covered in your report?
How do you present your
Disclosures?
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There are all sorts of disclosures such as:
○ Relationship disclosure information
○ Privacy Policy
○ Complaint handling
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What format do you use – booklet, stand
alone, a mix?
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How is evidence of client receipt obtained?
CRM 2
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What are you doing about cost disclosures
coming into effect on July 15 2014?
○ management fee
○ sales charge or deferred sales charge and any other
redemption fees or short-term trading fees
○ any trailing commission, or other embedded fees
○ any options regarding front load ends
○ switch or change fees
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Anything else re RDI or account statements?
Q&A
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Do you have any
questions?
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THANK YOU!