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

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

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

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

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

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?

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?

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?

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?

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?

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?

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?

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?

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