IIAC COMMENT LETTER FOR CSA STAFF NOTICE 31-358
Guidance on Registration Requirements for Chief Compliance Officers
IIAC member firms appreciate the CSA’s objective to provide firms with increased flexibility in how they implement Chief Compliance Officer (CCO) responsibilities to allow firms to better align the CCO position with their operational and business needs. In general, member firms believe the Multiple CCO and Specialized CCO models would be helpful for firms that have multiple lines of business or where firms seek to have a more specialized line of business.
The CSA also proposed a Shared CCO model. While member firms appreciate the intent of the model, most member firms did not believe this model would be workable among unaffiliated IIROC firms.
Please contact Adrian Walrath for more information.