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Bulletin | Covid-19

The CSA Postpone the Implementation Date for Client Focused Reforms

Fasken
Reading Time 2 minute read
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Investment Management Bulletin

In the context of the COVID-19 pandemic, the Canadian Securities Administrators (the "CSA") announced on April 16, 2020 two harmonized local blanket orders in connection with the implementation of the Client Focused Reforms (as defined hereinafter). Under the first one, the CSA have postponed from December 31, 2020 until June 30, 2021 the implementation of the changes to the conflict of interest provisions (the "Conflict of Interest Orders"). Under the second one, the CSA have postponed from December 31, 2020 until December 31, 2021 the implementation of the changes to the relationship disclosure provisions (the "Relationship Disclosure Orders"). Changes to the other provisions under the Client Focused Reforms will take effect as scheduled on December 31, 2021.

On October 3, 2019, the CSA adopted amendments to NI 31-103 to implement reforms to enhance the client-registrant relationship (the "Client Focused Reforms"). The main objective of these reforms is for the registrants to put clients' interests first when giving them investment advice and trading securities for them. 

The Conflict of Interest Order was granted in order to permit registrants to remain focused on current front-line activities, including the needs of their clients during the COVID-19 pandemic. However, registrants should keep in mind the Client Focused Reforms when interacting with clients, especially during the COVID-19 pandemic, as they expect more than ever to receive advice where their interests come first. The Relationship Disclosure Order was granted in order for the relationship disclosure provisions to be implemented at the same time as the know your product and enhanced suitability provisions in accordance with the output of discussions with industry stakeholders.

These blanket orders are available on each CSA member's website. Links to those of the Autorité des marchés financiers and the Ontario Securities Commission can be found here:

(AMF - French versions only)

Conflict of Interest Order: Décision générale relative à une dispense de certaines obligations du Règlement 31-103 sur les obligations et dispenses d’inscription et les obligations continues des personnes inscrites (PDF)  

Relationship Disclosure Order: Décision générale relative à une dispense de certaines obligations du Règlement 31-103 sur les obligations et dispenses d’inscription et les obligations continues des personnes inscrites (PDF)

(OSC

Conflict of Interest Order: Ontario Instrument 31-511 Relief in respect of Client Focused Reforms Conflict of Interest Provisions of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations  (PDF)

Relationship Disclosure Order: Ontario Instrument 31-512 Relief in respect of Client Focused Reforms Relationship Disclosure Information Provisions of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (PDF)

Should you have any question on the foregoing, feel free to contact any member of our Investment Management team.

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