Changes to RDBA Forms
New regulations
RDBA forms are being updated in order to be compliant with new regulations including those from FCAC, CRS and FINTRAC.
Re-design
We have had discussions with the Broker Advisory Group about re-designing the structure of RDBA Forms to allow Brokers and Affiliates to more easily re-use the same signed forms with multiple FIs. This re-design will reduce the amount of time Brokers and Affiliates need to spend meeting face-to-face with clients and getting their signatures.
New types of forms
The CICF is being split into 3, separate custodial forms:
- There is a new Client ID Verification Form (CIVF), separate from the CICF
- The Client Information and Consent Form (CICF) will now be one per person
- There is a new Joint Investment Agreement Form (JIAF) that all co-owners will sign, separate from the CICF
What’s a CIVF?
The new Client Identity Verification Form is where you document only the identity information about your client that never changes. With the old Client Information and Consent Form, the client’s ID information, address, employer and signature were all on the same form. Before, if your client changed employers, you would need to meet them in person to sign a new CICF. Now, with the CIVF, you can update your client’s information that may change from time to time without being required to meet them in person.
Re-papering clients
If a Deposit Broker has an old version of an RDBA CICF on file for a client, as long as the CICF has not expired, it is still valid. We are of the opinion that Deposit Brokers will not need to re-paper their entire client base when the new forms become available; they will only need to use the new forms moving forward. The same information that was captured in the old CICF will now be captured using more than one of the new forms and the same information will just be organized differently.
When will the new forms be available?
New FINTRAC regulations come into force on June 30th, 2017 and the new forms will be available in advance of this time.