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IIAC Activity Update
March 2015
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designates a new or amended entry
CSA - SRO Issues
Cooperative Capital Markets Regulatory System
The IIAC submitted comments on the draft Provincial Capital Markets Act and the Capital
Markets Stability Act in December 2014. The IIAC continues to support the objectives of this
initiative and the proposed legislation. The IIAC submission highlighted the difficulty of fully
assessing the draft legislation in the absence of detailed regulations. Further, we expressed
concerns that the transition and implementation not result in additional costs or impose
undue regulatory burdens on market participants. We also raised questions regarding how
participating jurisdictions will interact with non-participating jurisdictions. The IIAC plans to
comment on the draft regulations when they are released in the spring.
*IIROC Guidance on the Definition of Foreign Organized Regulatory Market (FORM) and
Southbound Trade Flow
In December 2014, IIROC expressed concern about trade flow in interlisted securities being
conducted in the US, and the effect of this on the Canadian securities markets. In response,
IIROC issued a notice setting out its interpretation of its rules relating to trading in the US on
FORMs. IIAC members were very concerned that this interpretation did not reflect long
standing practice, and would have detrimental effects on the ability of firms to achieve the
most efficient execution for clients in certain circumstances. The IIAC submitted a letter
explaining the issues and met with IIROC to discuss the areas of concern. IIROC is gathering
data and is expected to make a decision on this issue.
*IIROC Republication of Proposed Dark Rules Anti-Avoidance Provisions
IIROC re-published proposals initially proposed in 2012 that would limit the ability of a
Participant to execute small client orders on a foreign organized regulated market (FORM)
unless the order is executed on a market that displays order information or executed at a
better price. The IIAC re-iterated its comments that the proposals create a protectionist
regime that would have negative impacts, including a compromised ability to access
increased liquidity and achieve best execution, complications for third party foreign dealers,
technology changes and increased costs and prejudice to small Canadian investors.
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*CSA Amendments to the Rights Offering Regime
The IIAC supported CSA efforts to simplify the Rights Offering regime, and make it more
time and cost efficient to raise funds using this prospectus exemption. The proposed
amendments are consistent, and expand upon the new “existing shareholder exemption”
implemented by CSA members over the past year.
IIROC Consultation on Proficiency Assurance Model (Options for Other Education
Providers)
The agreement between IIROC and CSI to provide licensing courses and examinations
expires in January 2016. As a result, IIROC released a Consultation Paper evaluating the
current model and examining possible alternative approaches. The IIAC’s Proficiency
Assurance Model Working Group responded to the Consultation Paper which will assist in
informing IIROC in its deliberations.
*Client Relationship Model (See also Operational Assistance – Best Practices and Tools
below)
The IIROC CRM2 Rules for 2015 and 2016 were finalized on January 19, 2015 and IIROC
issued updated FAQs on February 9, with a few relieving measures. The IIROC CRM2 Rules
confirm that dealers have the opportunity to apply for an exemption if certain criteria are
met for client-name accounts (IIAC exemption application considerations document on
CRM2 Toolkit member webpage). The CSA agreed to the IIAC’s request for implementation
of the 2015 deliverables to align with 2015 calendar year-end, however, did not accept
calendar-year 2017 reporting. Extensive work by IIAC CRM2 committees continues. All retail
and integrated IIAC dealers are encouraged to participate in an IIAC committee to ensure
they are aware of changes currently under consideration.
Proposed Amendments to the Order Protection Rule (OPR)
IIAC responded to the CSA’s Proposed Amendments to NI 23-101 Trading Rules, which were
designed to address certain costs and inefficiencies related to the current application of the
OPR. The proposed amendments would impose a 5% market share threshold before
marketplaces would be designated as “protected marketplaces”, impose interim trading fee
caps, address concerns related to market data fees, and create a pilot project to review the
maker-taker fee model. The Association’s comments expressed general support for the
proposed amendments, provided they are implemented as a package to address the myriad
of issues. The CSA continues to review the feedback.
Short-term Debt Prospectus Exemptions
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In August 2014, the IIAC was invited by the CSA to provide additional comments on revisions
made to the Proposed Amendments to NI 45-106 Prospectus and Registration Exemptions
Relating to the Short-term Debt Prospectus Exemption and Proposed Securitized Products
Amendments. The majority of the revisions reflected concerns the IIAC had expressed in its
April 2014 Response Letter. The IIAC’s latest comments focused on clarifying requirements
and ensuring that the implementation and transition period will provide firms with sufficient
time to implement the proposed requirements without market disruption.
*Proposed New Prospectus Exemptions
The IIAC responded to proposals by the OSC and other securities commission to create or
amend proposed prospectus exemptions intended to facilitate capital raising by businesses
at different stages in their development. The four exemptions included an offering
memorandum exemption, a family, friends and business associates (FFBA) exemption, an
existing security holder exemption, and a two-tiered crowdfunding exemption. New
exemptions were introduced, including the OM exemption, existing shareholder exemption
and the FFBA exemption. The Commissions continue to review the proposed crowdfunding
exemptions. The Association expressed serious concerns that the proposals differed among
jurisdictions, leading to an inconsistent, confusing and inefficient patchwork of exemptions
that could hamper capital raising efforts. IIAC was also critical of the proposed
crowdfunding exemptions as they pose serious risks to investor protection.
* IIROC Issues Proposed Guidance Respecting Underwriting Due Diligence
IIROC published its Guidance Respecting Underwriting Due Diligence in December 2014.
The Guidance, which is not intended to set minimum or maximum standards or new legal
obligations, reflects many of the comments made by IIAC in its submission and in
consultation with IIROC on the content of the Guidance.
IIROC Debt Securities Transaction Reporting Rule
On October 30, 2014 IIROC published its Debt Security Transaction Rule (Rule 2800C). The
final rule reflects some of the comments previously submitted by the IIAC. Under the new
framework, Dealer Members will be required to report to IIROC, on a post-trade basis, debt
security transactions they execute and those of their affiliates that are Government
Securities Distributors (GSDs). The framework has been approved by the Canadian Securities
Administrators. By November 2015, all IIROC members that are GSDs will be required to
commence reporting into IIROC. All other IIROC members will be required one year later. A
proposed fee-model has also since been issued by IIROC outlining how IIROC envisages
recouping its cost for maintaining the system
*CSA Review of the Proxy Voting Infrastructure
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In early 2015, the CSA published Staff Notice 54-303 “Progress Report on Review of the
Proxy Voting Infrastructure”. In 2014, the IIAC provided written comment and participated
in various roundtables and the CSA’s Technical Working Group. The Report summarizes key
findings from these efforts, and outlines reasonable and practical next steps, including the
development of appropriate industry protocols to address the challenges identified in the
Report. The IIAC will continue to work with the CSA and other industry groups to develop
these protocols.
IIROC Proposed Provisions for Order Execution Services as a Form of Third-Party Electronic
Access to Marketplaces
The Association responded to IIROC’s proposal to implement specific supervision and client
identification requirements relating to Order Execution Services account activity. The
objective of the proposals is to achieve consistency in regulatory and supervisory
requirements across all forms of third-party electronic access to marketplaces. IIROCs final
regulation incorporated many of IIAC’s suggestions, and subsequently granted IIAC’s request
for an extension for firms requiring an extension for implementation.
CSA Modernization of Investment Funds
The IIAC responded in August 2013 to the CSA’s 2013 request for comments on the
proposed modernization of investment fund product regulation amendments, which would
have significantly affected members’ closed-end fund business. The IIAC supported
governance changes, but disagreed with new investment restrictions and requested the CSA
to clarify that no changes would be made for the period of time necessary to consult fully on
proposed limits and alternative funds, after which time any new regulation should
grandfather then existing funds. The CSA issued a final rule in June 2014 (with a September
effective date). As the IIAC requested, the issuer concentration restriction, illiquid asset
restrictions, and proposed organizational costs amendments were not enacted (although
may be republished for comment with the re-publication for comment of the alternative
funds proposals and interrelated investment restrictions, at a future date.
Unregistered Foreign Dealers in Foreign Listed Derivatives
Following an IIAC submission and subsequent discussions, the OSC published Staff Notice
33-744 dated September 18, 2014 that provides an interpretation of the unsolicited trade
exemption and the hedger exemption available to foreign dealers in connection with trades
in foreign listed derivatives. IIAC believes this severely narrows the scope of permitted
activities by unregistered dealers. In addition, amendments to National Instrument 31-103
released October 16 also include the removal of the “non-solicitation exemption” for trades
in exchange contracts in Alberta, British Columbia, New Brunswick and Saskatchewan.
These were previously widely used by U.S. FCMs to deal with Canadian investors. IIAC will
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continue to make representations to other CSA jurisdictions where similar exemptions are
still available.
Fiduciary Standard in Canada
The IIAC submitted a response to the CSA’s consultation paper regarding the
appropriateness and feasibility of introducing a statutory best interest duty for advisors in
Canada. The IIAC believes that Canada has been proactively advancing its securities
regulatory regime and that CRM will address investor protection concerns. CRM should be
fully implemented and evaluated prior to the consideration of new policy initiatives. In
addition, a cost benefit analysis must be conducted. The IIAC also believes a best interest
standard could result in potential unintended negative consequences for investors and the
industry. The IIAC and IFIC worked with Torys LLP on a research report that examined what
the actual standards for advisors are in other jurisdictions. The report concluded that
Canada’s regulations are equal to or more stringent than what other jurisdictions have
labeled a fiduciary standard. The report was provided to the CSA. The CSA recently released
a summary of the comments it received on its consultation paper and it stated in the next
few months it would decide what, if any regulatory actions it may take.
OTC derivatives reform
In line with Canada’s G-20 commitments, the CSA initiated a reform of OTC derivatives in
2010. The reform is expected to cover clearing, trade reporting, trading, capital and
collateral and registration. Although the reform initiative primarily targets the swap market
from which IIAC members are largely absent, they will apply to some members involved in
other types of – mostly retail – OTC derivatives and may impact listed derivatives.
IIAC and the Derivatives Committee have consistently argued that our members’ activities in
OTC derivatives do not raise any systemic risk issues and that IIROC already provides a
proven regulatory framework. We have therefore submitted that they should be exempted
form the CSA rules. We have also argued that a new registration regime is not required for
derivatives and that, at the very least, listed derivatives should be excluded form any
proposed new regime. IIAC will continue to lobby regulators for exemptions from OTC
derivatives rules on the basis that IIROC provides equivalent regulation.
New Issues Not Available in Quebec
Section 40.1 of the Quebec Securities Act mandates the translation of all prospectuses filed
in Quebec as well as all documents incorporated by reference. Because of this obligation,
half of new “national issues” are not filed in Quebec. As a result, Quebec investors are
largely excluded from the primary market. To address this problem, IIAC has recommended
the adoption of the “European approach” of translating only a summary of the prospectus.
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This issue will be pursued as part of a broader project of addressing the structural issues
that have contributed to a collapse of the IPO market in Quebec. IIAC will be collaborating
with other private sectors participants and government entities on that agenda.
Government and Tax Issues
Financial Planning
The Ontario government published a request for comments examining the merits of more
tailored regulation of financial planners. The IIAC prepared a response in January 2014,
which included general support for additional clarity and standardization for the provision
and supervision of financial planning in the industry. However, the IIAC made it clear that
individuals who are members of an SRO should be able to offer financial planning services
without an additional requirement to join another SRO for financial planning as this would
lead to unnecessary duplication and redundancy.
*Retirement Savings Reform – Pooled Registered Pension Plans (PRPPs) and Ontario
Retirement Pension Plan (ORPP)
In December 2014, the Ontario government released a consultation paper and introduced
legislation that would commit the government to establishing an Ontario Retirement
Pension Plan (ORPP) by January 1, 2017. The IIAC’s written response to the Consultation
Paper expressed disappointment at the haste in moving forward with the ORPP prior to the
government’s assessment and response to key questions raised in the IIAC’s submission. In
particular, if existing savings plans for employees, such as group RRSPs, are not deemed to
be “comparable plans” to the ORPP, the result will be reduced flexibility and choice for
employers and employees, and an overall weakening of the Ontario financial services sector
– a negative economic impact that will be felt across all of Canada.
Federal Budget 2015
The IIAC sent its pre-budget submission to the House of Commons Standing Committee on
Finance, and appeared before the Committee in October 2014 to present its
recommendations. The IIAC’s recommendations focused on promoting capital-raising by
lowering the capital gains tax, studying a U.K. model for supporting early stage companies
and pressing for the elimination of payroll tax on Group RRSPs to help businesses and put
them on a level playing field with PRPPs and other pension plans. . The Finance Minister
announced that the 2015 federal budget will not be tabled before April 2015.
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*High-Value TFSAs and Small Borrowings
The IIAC is continuing to work on a high-value TFSA matter that leaves dealers exposed to
considerable risk of loss. The IIAC submitted a letter to Finance to request that the liability
of industry members be limited through an amendment in to the Income Tax Act. Also,
clients are being penalized for minor inadvertent short-term borrowings (e.g., when a
client’s account is in a negative balance one day due to a settlement mismatch). IIAC staff
met with the CRA and Finance in late January 2014 and is following up regularly on this
important issue. The IIAC wrote to Finance and the CRA, as both legislative and
administrative solutions are required, in the summer of 2014, and raised the issue in an
October meetings with the CRA and Finance to pursue this issue further. The issue was
raised with Deputy Finance Minister Paul Rochon on November 19, 2014 and this was
followed up by a further submission in December to, and a meeting in January 2015 with,
Finance. The IIAC and members met on February 24 with senior Finance and CRA officials,
with positive signs in both cases. The IIAC sent follow-up letters in both cases and will
follow up to press further.
*Goods and Services Tax/HST Review
The federal government has begun began researching on the application of GST to
financial services, which has had gone un-reviewed in the 20 years since the GST’s
inception. IIAC met with, and made submissions on this matter. At present, there is
no interest expressed by members in changing the current exemption approach.
The IIAC received a request from IFIC for IIAC member views on making the trailer
taxable and circulated it to interested parties for their input: member views remain
the same, namely, no change in the current largely exempt treatment and process
for dealer services is wanted. Separately, the IIAC is requesting an update to the deminimis financial institution threshold definition to account for inflation since the
GST legislation was enacted: this is expected to assist some carrying brokers, and
through them, their introducing brokers.
U.S. Tax Reporting and Withholding -FATCA
In June 2014, the Canadian government passed legislation and published detailed
guidance to implement the intergovernmental agreement (IGA) with the United
States to facilitate the provisions of the Foreign Account Tax Compliance Act (FATCA)
in Canada. All Reporting Canadian FIs (which will include all IIROC registered
investment dealers) should have registered and obtained a GIIN by December 31,
2014. New FATCA compliant W-8BEN forms are also available on the IRS website,
along with detailed instructions on how clients should complete the forms. These
new forms should be in use for new account opening as of January 1, 2015. IRS
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Notice 2014-33 and the Canadian guidance allowed FIs to continue to document
entities as per existing procedures (W-8BEN and/or KYC) until December 31, 2014,
however, the FATCA status of those entities must be documented by the end of the
due diligence deadline for pre-existing entity accounts (i.e. by June 30, 2016).
In late June 2014, the IRS also published the revised Qualified Intermediary (QI)
Agreement, which has been amended to align with the FATCA requirements. All
IIROC dealers in Canada are currently QI compliant, and will have to carefully review
and consider changes required to comply with the revised QI Agreement (both
Carrying Brokers that act as QIs and the Introducing Brokers that must implement
certain account documentation and due diligence requirements). The standardized
IIROC IB-CB Agreements which currently contemplate U.S. tax withholding and QI
will require changes to incorporate the new QI Agreement and FATCA provisions.
IIAC is working with members, outside consultants and IIROC to facilitate these
revisions to the IB-CB Agreements.
OECD Common Reporting Standard (CRS)
In summer 2014, the OECD published a final version of the framework for a Common
Reporting Standard (CRS), which would require multilateral information sharing of
non-resident tax information (similar to FATCA) among all countries that adopt the
CRS and implement local legislation to implement the Standard. In October 2014, a
group of “early adopter” countries signed onto the CRS and committed to begin
sharing information in 2017. Other countries, including Canada, are committed to
begin sharing information in 2018. Canada is not expected to begin drafting any
specific implementing legislation or guidance before late 2015 at the earliest. The
IIAC has been providing industry comments and feedback on the timing and
implementation of the CRS to the Canadian Department of Finance and the Canada
Revenue Agency (CRA), and will continue to do so.
Federal Immigrant Investor Program (IIP)
In response to a request from a number of members, the IIAC wrote to the Minister
of Citizenship and Immigration Canada to recommend that the definition of the
program “Facilitators” be expanded to include IIROC-registered investment dealers
and request that the IIP application backlog be cleared expeditiously and fairly. The
Minister acknowledged the letter.
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T1135s
Starting last year, IIAC Member staff were approached by tax professionals seeking
help in completing CRA T1135s – Foreign Income Verification Statement – for clients.
While not a requirement for Member firms to report, the significantly more detailed
information required by the new forms demanded that clients seek extensive help
from Member firms to complete the form or risk increased penalties. The IIAC
achieved a simplified solution for 2013 reporting for IIROC dealers, which the
Taxation Reporting Committee estimates saved the industry several million dollars in
potential costs to help clients meet the requirements.
The IIAC proposed permanent reporting amendments in March 2014 to help clients
and dealers. A meeting with the Chartered Professional Accountants and the CRA
was held June 10, 2014 when the CRA provided changes that differed from both the
original, transitional and proposed approach. After Member firms assessed the
changes, it appeared that they would be difficult to accommodate in 2014. The IIAC
recommended the CRA make at least some changes or again adopt transitional rules
given the late receipt of information. The IIAC and CPA Canada sent a joint letter to
the Department of Finance to increase the T1135 reporting threshold, a measure
that would reduce work by advisors and dealers. Once the CPA advised the CRA that
6,000 (now 7,000) individuals have signed up for a T1135 webinar to be held
November 18, 2014, the CRA accepted to discuss what we hope will be FAQs that
can provide some streamlining. The CPA and IIAC met with senior CRA officials on
November 18 on technical and policy matters. The IIAC President will raised the
matter in a meeting with Paul Rochon, Finance Deputy Minister, on November 19,
2014 and IIAC staff continues to work with the CRA and CPA Canada to minimize
disruption to clients and cost for member firms.
Operational Assistance – Best Practices and Tools
For details, please refer to the IIAC Website
Canadian Anti-Spam Legislation (CASL) Toolkit
Client Relationship Model (CRM) Member Support
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In preparation:
• Market value checklist
• Considerations for market value policy and stale-dating matrix
• CCO Priority Examination Checklist
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CRM2 Member Status Survey
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Off-book/client-name exemption reporting “considerations”
Tip Sheets:
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CRM2 Toolkit (member-only website, Industry Impact, Key Issues, CRM)
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What you should know about CRM – one-page summary of CRM1 and CRM2
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Model CRM2 performance benchmark stuffers
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DOs and DON’Ts for investment advisors
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Debt trade confirmation mock-up
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Explaining difference between of time- and money-weighted rates of return
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Using Fund Facts for mutual fund and point of sale disclosure (optional)
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Template script for pre-trade disclosure (optional)
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Using required deposit-type investment regulation disclosure for pre-trade
disclosure (optional)
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Ways to encourage clients to bring client-name accounts on book
CRM2 Newsletter – CRM2 Countdown
Webinar: CRM2: What Advisors Need to Know – 1 CE credit
Webinar: CRM2: Cracking the Code – 1 CE credit
Webinar: ACB: Do Your Clients Pay Too Much Tax? (includes segment on challenges
of position cost) – eligible for .75 CE credit at firm discretion)
Pre-trade disclosure survey
Relationship disclosure benchmark wording
Annual compensation report prototype and data map
Annual performance report prototype and data map
CRM1 Toolkit
Enhanced suitability automation and standardization presentation
A conflict-of-interest “template” reflecting IIROC input
A conflict-of-interest self-assessment tool
An RD “considerations” document
Enhanced suitability roundtable
CRA Non-Resident Agreements
Referral Agreements and Disclosure Templates
Guidance on Compliance with CRTC Telemarketing Regulation (Do Not Call Rules)
Guidance Notes Added to IIAC New Issue Practices Handbook
(formerly Syndicate Practices Handbook)
IIAC Guidance Notice on the Québec Derivatives Act
Anti-Money Laundering (AML) Requirements
Marketplace Communications Protocol
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Product Due Diligence
Non Brokered Private Placement Best Practices
Outside Business Activities Template
Fixed Income Central Counterparty and Netting Utility
Model Securities Account Control Agreement
New York No-Action Letters
New Disclosure Requirements for Segregated Funds
Third Party Determination – Comfort Letter
Debt Syndication Practices
2013 Tax Reporting from Income Trusts and LPs
Publications
Securities Industry Savings-to-Investment Prosperity Cycle: Synopsis to help government,
media and other audiences understand the role of the securities industry. Providing a
snapshot of the securities industry, it highlights the members’ support for retail and
institutional clients, and how the industry connects savers and investors to help generate
economic activity and jobs.
Retail Publications
IIAC has issued a number of retail publications. The Retirement Planning Guide, Bonds: An
introduction to bond investing, Bonds: More on bond investing, the IIROC Registered
Advisor Advantage and the 5Ws of investing, Answering Your Questions are available on the
Publications page of www.iiac.ca.
The ‘Security’ in the Securities Industry Brochure: An investor awareness piece that
summarizes some of the major regulatory and structural elements unique to the Canadian
securities industry which safeguard investors. The two-page piece touches on the roles of
IIROC, CIPF, securities commissions and the clearing agencies.
Equity Capital Markets New Issue Practices (formerly Syndicate Practices Handbook): IIAC
has published the New Issue Practices which will help firms in improving the efficiency of
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the underwriting process, especially in the execution of bought deals. It will also provide
firms with a better understanding of their responsibilities in underwriting and selling newly
issued securities to the public by providing a baseline reference point for syndicate
managers to indicate possible differences from the normal practice.
Debt Markets Syndication Best Practices: IIAC has published Debt Markets Syndication Best
Practices which illustrates industry “best practices” in the syndication of corporate and
provincial debt offerings. The document was prepared by a working group of industry
professionals under the auspices of the IIAC and is available on the IIAC website.
Value of Advice: The IIAC has assembled results from a range of studies regarding the
quantification of the value of advice on financial outcomes for Canadians. This can be useful
for advisors or members’ communications or newsletter purposes.
2015 CEO Survey: On January 8, 2015, the IIAC released the results of IIAC 2015 Capital
Markets Outlook: A Survey of Canada's Investment Industry CEOs. The survey results show
Canada’s investment industry CEOs are optimistic about the outlook for capital markets and
their individual firms in the coming year.
Protecting Senior Investors Report: On March 18, 2014 the IIAC released a guidance report,
entitled Canada’s Investment Industry: Protecting Senior Investors, to share best practices
investment dealer firms and advisors are using when working with senior clients. The report
underscores how seriously the industry takes its responsibility to ensure senior investors are
being served in an ethical, respectful and informed manner. It also calls attention to the
important role firms and advisors are playing in protecting this client base.
Industry Profile-Building Initiatives
*IIAC Media Advocacy: On March 11, Ian Russell, IIAC President and CEO, appeared on BNN
to talk about tax revenue losses from TFSA accounts. In an opinion piece in the Financial
Post on March 10, he argued these tax losses from TFSAs were overstated, supporting the
case for retention of TFSAs and the government’s commitment to double the annual
contribution limit.
*IIAC’s Ian Russell Addresses the Prospectors & Developers Association of Canada
(PDAC)'s 2015 Convention: In his speech at PDAC's 2015 Convention, Ian Russell, IIAC
President and CEO, noted that Canada’s investment industry is prepared to invest the time,
energy and resources to improve capital raising for the mining industry, but it can’t do it
alone. Russell offered a series of regulatory and policy fixes which, if adopted, will get the
Canadian mining industry back on track.
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*IIAC Calls for 2015 Investment Industry Hall of Fame Nominations: The IIAC has begun
accepting nominations for the 2015 class of Hall of Fame Inductees. Details regarding the
nomination process, including criteria, are available here. Said Ian Russell, IIAC President
and CEO: “Our Inductees are visionaries who have had success in business and applied it to
the needs of their communities. They have strongly contributed not only to the growth and
prosperity of our industry, but also to the building of Canadian businesses and financial
security of many Canadians. These individuals represent the core values of our industry:
Excellence, innovation and integrity.”
*IIAC Letter from the President
Since the last IIAC Activity Update, Ian Russell, IIAC president and CEO, penned two Letters
from the President focusing on issues of importance to the investment industry:
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V82 – Evolving Structural Change in Financing and Trading in the Venture Capital
Markets (March 2015)
V81 – Economic Growth: How to Renew it and Sustain it? 2015 Asian Financial
Forum, Hong Kong (January 2015)
*IIAC in the News
In Q4 2014, the IIAC was mentioned in 145 media stories, generating 40,575,561 total media
impressions. 100% of coverage was positive or neutral in tone; 100% of articles featured the
IIAC’s key messages.
*Upcoming Seminars/Events
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March 25-26, 2015: Canadian Institute FATCA Compliance Conference: Andrea
Taylor co-Chair and moderator (Toronto)
March 31, 2015: Implementing CRM2: Traps and the Tips and Tools to Avoid Them
(Toronto)
April 1, 2015: Compliance and Operations Symposium (Toronto)
June 4, 1015: IIAC Cyber Security Conference (Toronto)
TBA: IIAC Small and Independent Dealers Symposium (Toronto)
October 29, 2015: IIAC Investment Industry Hall of Fame Dinner Gala (Toronto)
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