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Canadian securities regulators announce guidance that will allow firms to implement more flexible Chief Compliance Officer arrangements

  • Securities - CSA Image

Jul 02, 2020

On July 2, 2020, the Cana­dian Se­cu­ri­ties Ad­min­is­tra­tors (CSA) announced guidance that will allow firms to implement more flexible Chief Compliance Officer (CCO) arrangements that better align with their operational needs and business models.

The guidance published outlines three CCO models tailored to the needs of small businesses, specialized businesses, and firms with multiple lines of business. CSA staff have provided guidance on arrangements where:

  • an individual can apply to be the CCO for more than one firm (the shared CCO model);
  • a firm can have multiple CCOs, each responsible for a separate business line or category of registration (the multiple CCO model); and
  • a non-traditional or specialized firm, such as a fintech firm, can have an individual acting as a CCO, with the individual’s industry-specific experience being used to assess their proficiency to act as CCO (the specialized CCO model).

Firms interested in implementing one of these arrangements must clearly demonstrate the model is appropriate for their business, as well as ensure individuals applying to be a CCO meet registration requirements.

Firms must first apply for registration or exemptive relief for these models, which will be reviewed by CSA staff on a case-by-case basis, to ensure requirements, including investor protection measures, are met. Registrants are encouraged to reach out to their local regulator for any questions they may have around these CCO models, or other relevant CCO models.

Re­view the press re­lease on the CSA's web­site and details of the guidance on the OSC’s website.

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