Registered Deposit Brokers Association members have benefited over the years from Anti-Money Laundering training and industry standard forms, and these have been at the core of membership value. RDBA has developed these solutions specifically for the Canadian Deposits Industry with input from Brokers and Financial Institutions as a set of best practices. Staying compliant with regulations and observing these best practices through RDBA membership helps members build credibility and establish trust with their clients. RDBA will continue to build on these core values with the modernization of our forms.
RDBA forms have always been reviewed and updated whenever there are any changes to relevant regulations. So with the FINTRAC rule changes that were released in June 2016, we are taking the opportunity make some additional changes to the forms that will benefit Deposit Brokers in the long run.
New Methods for Identifying Clients
RDBA forms will be updated to include options for all three acceptable methods of identifying clients:
- Photo ID Method
- Dual Process Method
- Credit File Method
Photo ID Method: this is already standard practice and will continue to be acceptable under FINTRAC rules.
Dual Process Method (New): a combination of approved documents will be considered acceptable as ID. Together, documents must contain:
- Name & address + name & date of birth; or
- Name & address + name & confirmation of financial account; or
- Name & date of birth + name & confirmation of financial account
Credit File Method (New): clients can challenge a series of questions to which whey would only know the answers. Clients access these questions using electronic means, and their answers are checked against Credit Bureau records for a match.
These new methods will open up the possibility for Deposit Brokers to verify a client’s identity through non-face-to-face or electronic means and reduce the need to meet with clients in person.
For more information on these changes, see the FINTRAC Guideline: Methods to ascertain the identity of individual clients.
Changes to Forms’ Structure
At the request of Brokers, the forms will be re-formatted to reduce duplication of client information and designed to be easier to re-use when a client is investing with multiple FIs.
The CICF will be split into 3:
- Client Identity Verification Form
- Client Information and Consent Form
- Joint Investment Agreement Form
Client Identity Verification Form
This will be a form that only contains the Client’s name, DOB and a record of the details of the ID verification.
- If the Photo ID method was used, then the type, ref#, place of issue and expiry date is recorded
- If the Dual Process Method was used, then the document type and ref# for each is recorded
- If the Credit File Method was used, then the credit bureau name, credit file inquiry ref# and date of verification is recorded
If a client changes their address or employment, then the Deposit Brokers could update this information through mail, courier or electronic means and would not be required to see the client in person. In the case of Photo ID method, Deposit Brokers would only need to see clients in person once for the life of the client’s photo ID.
Client Information and Consent Form
The new CICF will be designed as one per person. It will contain all the client’s personal information (address, employment, etc.) except for the ID verification information. The CICF will have a check box for ‘Client ID Verification Form attached.’ The new CICF will only contain disclosures for use of the client’s Personally Identifiable Information (PII).
Joint Investment Agreement Form
This form will contain the names, dates of birth and signatures of all joint owners along with the registration details for joint ownership and beneficiaries.
Other Form Improvements
All RDBA forms will be designed to accept electronic signatures. A Blakes report tells us:
“The Regulations change the definition of “signature card” to include “electronic data” that constitutes the signature of a person authorized to give instructions in respect of the account. In addition, a “signature” is now defined to include an electronic signature or other information in electronic form that is created or adopted by a client and that is accepted by the regulated entity.”
Forms will also be re-designed so all form fields can be electronically pre-populated.
RDBA forms are currently under review. Updated forms will be available in the first half of 2017.
*This article has been updated from a previous version that was emailed to RDBA members in RDBA Communication 16/11/2016. This version contains clarified language around Credit File Method and the quote from Blakes has been replaced by a more recent one from the same author.