IIAC COMMENTS ON ENHANCING THE PROTECTION OF OLDER AND VULNERABLE CLIENTS
The IIAC submitted a comment letter to the CSA on proposed amendments to National Instrument 31-103 to enhance the protection of older and vulnerable clients on behalf of our members.
Generally, our members are supportive of taking reasonable steps to obtain a trusted contact person (TCP) from a client and applying a temporary hold for the purchase or sale of a security, or withdrawal or transfer of cash or securities, from a client’s account.
The IIAC suggested that the implementation of a safe harbour provision would help so a firm would not face the prospect of litigation or a complaint when a firm initiates a temporary hold and has acted with a reasonable belief and in a manner that is consistent with its obligation to deal fairly, honestly and in good faith with the client.
The IIAC outlined areas our members believe there is a need for more guidance from the regulators. These include: