Compliance Questionnaire - Securities dealer sector

Part A - General Information

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Organization's legal name and Head Office address

Please indicate the type of premises for the above Head Office address
Commercial / Retail
Residential / Dwelling House
Other

Name and title of the individual completing the questionnaire
Business telephone
Business fax
E-mail

A1 - What is your principal business?
Securities Broker or Dealer
Mutual Fund Dealer
Investment Counselling / Portfolio Management
Financial Planning Services
Life Insurance
Other

A2 - What is your secondary activity? (check all that apply)
Securities Broker or Dealer
Mutual Fund Dealer
Investment Counselling / Portfolio Management
Financial Planning Services
Life Insurance
Other

A3 - What are you or your company licensed to sell? (check all that apply)
Equities
Fixed Income Securities
Investment Funds (Mutual Funds, LSVC Funds, Etc.)
Segregated Funds
Life Insurance products
Derivatives
Other

A4 - Who regulates you? (check all that apply)
Investment Dealers Association
Provincial Securities Commission
Provincial Financial Services Commission
Autorité des marchés financiers
Mutual Fund Dealers Association
Office of the Superintendent of Financial Institutions
Provincial Insurance Council
Other

If you are registered as a Investment Counsel / Portfolio Manager, please answer the following questions. If not, please go to question A7.

A5 - If you are registered as an Investment Counsel / Portfolio Manager, do you act solely in a sub-advisory capacity?

A6 - If registered as an Investment Counsel / Portfolio Manager, what type of business do you conduct? (check all that apply):
Private Clients
Institutional Accounts
Mutual Fund Management
Hedge Fund Management
Services and/or products offered through offshore jurisdictions

A7 - If you are licensed to sell Life Insurance products, do you act as (check all that apply):
Exclusive Agent
Broker
Other (please specify______________________________ )

A8 - How many employees are there in your organization? (including agents, advisors, brokers, etc.)

A9 - Please indicate the approximate value of assets under your management: $

A10 - Please indicate the average monthly trading volume your organization conducts:

A11 - Does your organization have branches operating in Canada?

A12 - If you answered yes to question A11, how many branches?

A13 - If you answered yes to question A11, in which provinces/territories do you operate branches? (check all that apply)

A14 - Does your organization have branches outside Canada?

A15 - If you answered yes to question A14, please list the other countries where the branches are located.
If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A15.

A16 - If you answered no to question A14, do you open or manage accounts for clients residing outside of Canada ?

A17 - What type and number of client accounts do you open or manage? (check all that apply)
Retail
Institutional
Other (please specify _________________ )

A18 - Has your organization been subject to an anti-money laundering compliance review by your regulator since June 12, 2002?

A19 - If you answered yes to question A18, what is the name of the Regulator and the date of the last review?

A20 - What is your organization's primary bank / credit union / caisse populaire / trust company?

A21 - What is your organization's secondary bank / credit union / caisse populaire / trust company?

A22 - Is your organization a subsidiary of any other entity subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If so, what is the name and address of the parent organization?

A23 - Does your organization own any other entities that are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If so, what are the name and address of these entities? If there is not enough room here, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A23.

A24 - Is your organization engaged in any other activities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? (eg. foreign exchange, funds transfer, real estate, etc.). If so, please list.

Part B

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B1 - Have you fully implemented a compliance regime in your organization? Refer to FINTRAC's website Guideline 4 at
http://www.fintrac-canafe.gc.ca/publications/guide/Guide4/4-eng.asp

B2 - If you answered no to question B1, at what stage of implementation is your compliance regime? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer B2.

B3 - Have you appointed a compliance officer to meet your reporting, record keeping and client identification obligations?

B4 - If you answered yes to question B3, please provide the name of the compliance officer.

B5 - Does your compliance officer report directly to senior management of the organization? (Senior management could be the owner or chief operating officer of the business, any senior executive or any member of senior management or the board of directors)

B6 - How does your organization keep up with any changes in reporting, record keeping or client identification obligations? (check all that apply)
Media (newspaper, television, etc.)
FINTRAC's Web site
Other websites
Seminars, training or conferences
Other

B7 - Have you consulted the FINTRAC Guidelines?

B8 - If you answered yes to question B7, do you find them useful?

B9 - Do you have any suggestions for improving the guidelines?

Part C

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C1 - Do you have policies and procedures to ensure your reporting, record keeping and client identification requirements are being met?

C2 - Are your policies and procedures in writing?

C3 - Within the last twelve months, has your organization conducted financial transactions with individuals or entities based in any of the countries on the Financial Action Task Force (FATF) List of Non-Cooperative Countries or Territories? For information about this list, please refer to FINTRAC's advisories at
http://www.fintrac-canafe.gc.ca/publications/avs/1-eng.asp

C4 - If you answered yes to question C3, which countries were involved and approximately how many transactions were conducted with each country? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer

C5 - Does your organization cross-reference the names of clients with any anti-terrorism lists of names published by the Canadian government? For more information about these, please refer to the List of Names Subject to the Regulations Establishing a List of Entities made under subsection 83.05(1) of the Criminal Code or the United Nations Suppression of Terrorism Regulations provided by the Office of the Superintendent of Financial Institutions at http://www.osfi-bsif.gc.ca

Part D

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D1 - Have you implemented a process for reviewing your organization's compliance policies and procedures to determine their effectiveness?

D2 - Has such a review already been conducted for your organization?

D3 - If you answered yes to question D2, how often do you conduct a review?
More than once a year
Once a year
Less than once a year

D4 - If you answered yes to question D2, the review was conducted by: (Check all that apply)
Compliance officer
Internal Audit
External Audit
Consultant
Other

D5 - If you answered yes to question D2, when was the review completed?

D6 - Are the results of the review documented?

Part E

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E1 - Does your organization provide training regarding your reporting, record keeping and client identification obligations?

E2 - If yes, describe how your training is delivered. Include information about the mode and frequency of delivery as well as a general description of who is required to take the training. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer E2.

Mode of training (check all that apply)
Self-directed
In a classroom with trainer/seminar
Computer-based
Other

Frequency of training
Annually
More often than annually (quarterly, etc.)
When new staff is hired
In special circumstances (Specify circumstances)
Other

Who receives the training (check all that apply)
Only those in contact with clients
All staff
Managers
Back office staff
Corporate security
Other

Type of material (check all that apply)
Handouts
Test administered with pass or fail mark
Presentation or group discussion
Other