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Published byGilbert Matthews Modified over 9 years ago
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CRM2 – Conforming Amendments to MFDA Rules May 2013 – MFDA Bulletin issued requesting Member feedback on specific areas of NI 31-103 that require clarification Contacting CSA staff to ensure consistent interpretation of requirements 0
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CRM2 – MFDA Conforming Amendments Conforming Amendments to MFDA Rules – 2 Phases Phase 1 amendments: conforming changes made to Rules: 2.2.5 (Relationship Disclosure) 2.4.4 (Transaction Fees or Charges) Published for comment October 10, 2013 – awaiting CSA Approval 1
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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
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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
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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
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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
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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
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