FOR DEALERS, ADVISERS AND INVESTMENT FUND MANAGERS
On October 14, 2022 the Compliance and Registrant Registration (CRR) Branch of the Ontario Securities Commission (OSC) published their Annual Summary Report for fiscal year 2021-2022, highlighting common registration and compliance deficiencies and identifying significant initiatives impacting registrants.
Unique in this year’s report are the preliminary findings of the in-process sweep of firms with limited compliance staff, where the focus was firms with a small number (≤ 1 FTE).
Also cited were notable deficiencies related to the new Conflict of Interest obligations introduced by the Client Focused Reforms, inadequate compliance protocols for marketing material, lack of suitability assessments for client directed trades, and insufficient supervision of unregistered consultants that were conducting registerable activities, among others.
IIAC Members are reminded that the CSA considers these annual reports as instructed guidance, and therefore we strongly encourage a review of your internal practices against the findings noted within this report so members may proactively address potential deficiencies.