Registered in Registered in Nominee Name Client Name
A. Transactions prior to September 1, 1996
All mutual fund transactions that were ‘off-book’ as defined in IDA Compliance Interpretation Bulletin C-93 prior to September 1, 1996, for which Member firms’ registered representatives accommodated client mutual fund transactions directly between the mutual fund company and their clients without opening an account at the Member firm.
i) Are Member firms required to reconstruct and maintain historical mutual Not applicable* No fund security position records for trades prior to September 1, 1996?
For Contractual {pre-authorized chequing (PAC)/automatic withdrawal (AWD)} Plans set up prior to September 1, 1996 where clients purchase or redeem set amounts of mutual funds on a regular or predetermined basis and the cash is drawn directly by the Fund Company from the client’s bank account or forward to the client’s bank account from the fund company:
i) Are Member firms required to open an account? Not applicable* No ii) Are Member firms required to record transactions for this plan? Not applicable* No iii) Are Member firms required to maintain a mutual fund security position Not applicable* No
record?
For mutual fund purchases after September 1, 1996 in Non-Contractual (regular investment accounts or client self-directed registered retirement savings plans (RRSP) held at a fund company) accounts that exist prior to September 1, 1996:
i) Are Member firms required to open an account for the client on their Not applicable* Yes (Cash
books? accounts)
ii) Are Member firms required to record mutual fund transactions in this Not applicable* Yes account?
iii) Are Member firms required to maintain a mutual fund security position Not applicable* No record?
B. Purchases on or after September 1, 1996.
All Member firms are required by SRO rules and Provincial Securities Acts to: Open client accounts;
Maintain “Know Your Client” information; Record transactions;
Generate and issue trade confirmations and account statements. a) Contractual Plans opened on or after September 1, 1996:
i) Can cash be sent directly to the Fund Company from the client’s bank Yes, however, the Yes, however, the
account? first transaction first transaction
ii) Are Member firms required to open an account on their records? Yes Yes iii) Are Member firms required to record any transactions? Yes Yes, for the first
iv) Are Member firms required to send trade confirmations and account Yes, for the first Yes, for the first
statements to each client? transaction and transaction.
v) Are Member firms required to maintain a security position record? Yes No b) Non-Contractual Purchases on or after September 1, 1996:
i) Can cash be sent directly to the Fund Company from the client’s bank No No account?
ii) Are Member firms required to open an account on their records? Yes Yes
iii) Are Member firms required to record any transactions? Yes Yes
iv) Are Member firms required to send out trade confirmations and account Yes Yes statements to clients?
v) Are Member firms required to maintain a mutual fund security position Yes No record?
must be booked must be booked by the Member by the Member
firm. firm.
thereafter written summaries of trades every six
months.
C. GROUP RRSP
Self-Directed Group RRSP’s at the Fund Company are held in client name only and may be in contractual or non-contractual form. All Member firms are required by SRO rules and Provincial Securities Acts to:
Open cash account for each participant; Maintain “Know Your Client” information; Record transactions;
Generate and issue trade confirmations and account statements. For contractual group RRSP plans, please refer to Section B, Part a). For non-contractual group RRSP plans, please refer to Section B, Part b). D. Redemptions
For redemptions of mutual fund units held in regular Investment accounts or client requests to set up automatic withdrawal plans:
i) Are Member firms required to record any transactions? Yes No, security
ii) Are Member firms required to send trade confirmations and account Yes No statements to client?
iii) Are Member firms required to maintain a security position record? Yes No position does not exist on the books
E. Client self-directed RRSP Transfers
For client self-directed RRSP transfers where the authorization to transfer the account is duly executed by the client, all Member firms are required by SRO rules and Provincial Securities Acts to:
Open client accounts;
Maintain “Know Your Client” information; Record transactions;
Generate and issue trade confirmations and account statements. a) Dealer to dealer transfer of client self-directed RRSP.
Account held at the fund company, where the only change involved is the dealer/Member firm code and the registered representative code.
i) Are Member firms required to open an account on their books? ii) Are Member firms required to record the transfer on their books? iii) Are Member firms required to record subsequent transactions? iv) Are Member firms required to send trade confirmations and account
statements to clients for subsequent transactions?
v) Are Member firms required to maintain a mutual fund security position record?
b) Transfer of a client self-directed RRSP at a financial institution to a client self-directed RRSP at a fund company on the advice of a Member firm’s registered representatives.
For example, cash from a maturing registered product (Term Deposit/GIC) in a client self-directed RRSP account at the financial institution to mutual fund units in a client self-directed RRSP account at the fund company.
i) Are Member firms required to open an account on their records? ii) Are Member firms required to record the transfer?
iii) Are Member firms required to record subsequent transactions? iv) Are Member firms required to send trade confirmations and account
statements to clients for subsequent transactions?
v) Are Member firms required to maintain a mutual fund security position record?
Not applicable* Yes, cash Not applicable* Not applicable* Not applicable* Not applicable* Not applicable* Not applicable* Not applicable* Not applicable* Not applicable* account. No Yes Yes No
Yes, cash account No Yes Yes
No
F. Switch transaction
For switch transaction which comprises a redemption and a purchase within the same client account and the same fund company involving any combination of equity, money market and next day pricing funds. All Member firms are required by SRO rules and Provincial Securities Acts to:
Maintain “Know Your Client” information; Record transactions;
Generate and issue trade confirmations and account statements.
i) Are Member firms required to record any transactions? Yes No, security
ii) Are Member firms required to send trade confirmations and account Yes No statements to client?
iii) Are Member firms required to maintain a mutual fund security position Yes No record?
position does not exist on the books
of the Member.*
G. General
Is the filing for exemptions to the Provincial Securities Commissions on hold? Yes, pending decision from CSA on
Are Member firms required to send trade confirmations for dividend reinvestments? No, dividend reinvestment is an this matter.
entitlement not a purchase.
*However all Member firms must maintain “Know Your Client” information to ensure the suitability of the purchase side of the switch transaction.
