CRM2 – Conforming Amendments to MFDA Rules May 2013 – MFDA Bulletin issued requesting Member feedback on specific areas of NI that require clarification Contacting CSA staff to ensure consistent interpretation of requirements 0
CRM2 – MFDA Conforming Amendments Conforming Amendments to MFDA Rules – 2 Phases Phase 1 amendments: conforming changes made to Rules: (Relationship Disclosure) (Transaction Fees or Charges) Published for comment October 10, 2013 – awaiting CSA Approval 1
CRM2 – MFDA Conforming Amendments 2 Phase 2 amendments: to be brought forward in June 2014 Phase 2 amendments will address: Client statement requirements Performance reporting Charges and Compensation Report
Drafting Considerations MFDA Members – Multiple Registration Over 80% of Member AUA – Client Name Over 90% of Member AUA – Mutual Funds Current reporting – client statements reflect all transactions through the Member 3
CRM2 –Phase 2 Amendments Discussion Paper to solicit preliminary comment from Members re: Scope of Client Reporting: 2 Main Considerations: 1) All Securities (all client name) 2) Investment Products sold through the Member 4
Next Steps April - Preliminary Consultation on scope of client reporting options May – Proposed Amendments – review by Policy Advisory Committee June – Proposed Amendments – review by Board of Directors Filed with CSA - Published for comment – 60 – 90 days Focus on Education/Guidance for Members on new requirements 5
CRM Implementation Considerations Data Collection/Integrity/Storage Reliance on 3 rd parties for information Disclosure of Securities subject to a DSC on Account Statement Referral Arrangements Performance Reporting – Money Weighted Method Consistency of Reporting – Members and Approved Person reports Electronic Delivery 6