1. The Good, the Bad, The Co$tly
COMPLIANCE
“OWN IT”
The Good, the Bad, The Co$tly
Moderator: Gary Legault, Legault Compliance Consulting

2. The Good, the Bad, the Co$tly
Panelists:
Manny DaSilva Canfin Magellan Investments Inc.
Ken Parker Portfolio Strategies Corporation
David Grad Primerica Financial Services (Canada) Ltd

3. How Are You Handling: Signature Falsification
Internal Strict Supervision
Position of Influence Assessments
POS Delivery of Fund Facts
Complaint Handling – Client Contact
FATCA
Client Risk Assessment
Pre Trade Disclosure of Fees and Charges
Concentration Risk
Titles Targeting Seniors

4. Signature Falsification
How does this ever come to your attention?
What investigation steps do you take?
What challenges are you facing?

5. Internal Strict Supervision
Do you have policies and procedures for internal strict supervision?
Who determines internal supervision?
What forms does it take?

6. Position Of Influence Assessment
Is this well defined and understood within the firm?
How is it disclosed?
Who assesses it and what is considered?
Any examples of restrictions or conditions imposed?

7. POS Delivery of Fund Facts
What are your firm’s policies and procedures for delivery?
How do you monitor and enforce delivery?
How are going to handle exemptions?

8. Complaint Handling – Client Contact
Is this standard practice and, if not, when is it required?
Is KYC information on file verified with all complainants?
What issues or concerns do you have with direct client contact?

9. FATCA What changes have you made to KYC collected?
What changes were made to systems and reports?
Have you experienced any regulatory and/or client issues or concerns?

10. Client Risk Assessment
What does your firm do to assess client risk – DR interview, risk profile form, HO client contact?
Should there be a standard prescribed risk assessment form used by all MFDA member firms?

11. Pre-Trade Disclosure of Fees & Charges
What is disclosed for what products?
Are estimates provided?
Do you disclose tax implications?
How is it delivered, explained, and evidenced?

12. Concentration Risk
Do you have any specific policies, procedures and training?
Are exempt securities, high risk mutual funds or any other products subject to concentration risk limits and assessment?
If so, how do you monitor them?

13. Titles Targeting Seniors
Do you have any specific policies and procedures?
Do you permit titles and/or initials after the DRs name?
Do you require proof of designation?
Do you update on NRD?

14. Q & A
Do you have any questions?
THANK YOU!