As we approach the end of the second quarter, it is a good time for registered firms to reflect on whether they have completed appropriate training for employees. Under National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103), firms are expected to provide training on specific topics. At a minimum, firms must provide training on conflicts of interest (COI), know your client (KYC), know your product (KYP) and suitability determination obligations during the year. As noted in our article above regarding the BCSC's annual Compliance Report Card for 2022, COI was one of the top areas where the most deficiencies were found. The BCSC and other securities regulators can impose significant administrative penalties for contraventions. The Ontario Securities Commission has also signaled in recent annual reports and in their Statement of Priorities for 2023 that COIs are high on staff's radar.
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