Firm Application Registration Guidance

This section to help guide new registrants through our vigorous registration process. 

The better informed we are about your business before you register, the better we can allocate our resources to ensure we are full filling our mandate. Also it will increase your ability to stay compliant with securities regulation.

What Do We Look for in a Business Plan?

  • executive summary
  • nature of the business
  • mission statement (philosophy)
  • identify shareholders, affiliates, related parties, management, and permitted individuals; provide background on management and permitted individuals
  • organizational chart and ownership chart
  • related party chart
  • business objectives (short and long term)
  • market analysis
  • target market
  • business goals and strategies (short and long term on how objectives will be achieved), including strategy implementation)    
  • marketing (what and how)
  • policies and procedures (Set out in a separate PPM)
  • human resources plan (recruitment, training and staffing)
  • three-year financial projection
  • risk management (identify business and operational risks and how they will be addressed)
  • timetables and milestones

What do we look for in a Policy & Procedure Manual (PPM)?

  • compliance function and process
  • ultimate designated person’s (UDP) responsibilities and duties (daily monthly and annual)
  • chief compliance officer’s responsibilities and duties (daily monthly and annual)
  • PPM updates and acknowledgement to read?
  • branch and head office supervision
  • registration and renewal of registration
  • new account opening procedures, including know-your- client (KYC) and suitability (cradle to grave account opening process)
  • account supervision
  • KYC update process (including how often)
  • money laundering and anti-terrorism compliance
  • proxy voting
  • outside business activities
  • custody and segregation of client assets
  • trade confirmations and account statements
  • disclosure when recommending related party or connected securities
  • subscriptions and redemptions (cradle to grave process, including documents that need to be completed)
  • personal trading
  • insider and early warning reporting
  • disaster recovery and business continuity plan (including incapacitation of key personal)
  • oversight of outsourced services
  • adverting sales communication and other client commutations
  • complaints
  • referral arrangements and, if applicable, soft dollar arrangements
  • borrowing for securities purchases and disclosure to clients
  • human resources (hiring and training)
  • conflicts of interest and disclosure to clients
  • tied selling
  • capital requirements, monitoring capital adequacy, and how excess working is calculated
  • bonding and insurance
  • books and records


When considering your application we may want to meet with the CCO and UDP of the firm to understand the firm’s business objectives.