March 2014

 Documentation is everything - If you can’t prove it, it didn’t happen  Insurer reviews  Regulatory audits  Lawsuits and E&O  FINTRAC Administrative Penalties

 Name a compliance officer  Document procedures  Train employees  Assess Risk  Self-assess every 2 years See Anti-Money Laundering on BridgeForce Compliance site

- Follow a consistent, documented process – Demonstrate why your recommendations are suitable. - Ensure customer understands and signs key documents. - Keep copies for audit and legal purposes. See the BridgeForce Compliance tab on the website.

- Use only the name on your license (Ontario). No unlicensed trade/marketing names. - Don’t mislead the customer about your credentials and offerings. They need to know you are an insurance agent. - Don’t use bogus "designations" that are aimed at a vulnerable demographic (i.e. seniors designations).

 Fact-find and assess needs before recommending a product, concept or action (including segregated funds).  If you hold out as an Advisor, maintain current information about customers that allows you to ensure ongoing suitability of your recommendations or to make adjustments. See Needs Analysis and KYC on BridgeForce Compliance site.

 Use the required forms and explain the advantages and disadvantages of replacement to the customer.  Replacement is a suitability issue. Make sure your recommendations are suitable. See Replacements on the BridgeForce Compliance site.

Segregated funds are insurance products.  Fact-find and needs analysis – demonstrate why recommendation is suitable in comparison to other choices.  Provide the required documents at time of sale. See Needs Analysis and KYC and Point of Sale Disclosure on BridgeForce Compliance site.

You are required to disclose, in writing 1. The companies whose products you promote 2. All of the ways you are compensated (including conferences and travel and other incentives) 3. Any potential or real conflicts of interest 4. That customer has the right to ask for more information. See Point of Sale Disclosure on BridgeForce Compliance site.

 Disclose why you collect and use personal information and obtain customer consent (PIPEDA).  Effective July 2104, you must have customer consent to communicate electronically (ANTI- SPAM). Non-compliance carries severe penalties  See Advisor Privacy Statement and Consent Template in Point of Sale Disclosure on BridgeForce Compliance site.

 Disclosure documents – use your own or the BridgeForce template we make available  Privacy and anti-spam statements and consents - use your own or the ones we provide Compliance officers from BridgeForce and the insurers are available to assist you in updating or even creating your own material.

 Covers the requirements.  You must customize it to fit your practice.  Give a lot of thought to potential conflicts of interest.  Get customer to sign and retain a copy for your files.

◦ Disclosures and consents for sharing info. with MGAs  assignment of policy (retirement, death, incapacity)  collection/use of personal information, including consent to retain copies of applications and medical information.  communicating electronically.