Introduction

Dealer Member Rule 2900, Part III sets guidelines for continuing acceptable education course content, length and rigour which each Member must comply with if practicable. The guidelines also recommend a process to aid firms in identifying appropriate suppliers and courses.

The parameters and guidelines should be considered in the context of what is appropriate to the individual, his or her position and responsibilities, and the needs of the firm. This can best be accomplished by each firm allocating responsibility to a single person for defining training needs and appropriate programs to address them. Depending on the firm, some responsibility for approval of an individual’s program may be delegated to the appropriate supervisor.

As part of the audit process, IIROC will review a firm’s continuing education program to ensure that it is properly documented and satisfies the guidelines.

 THE COMPLIANCE COURSE

A. BASIC PRINCIPLES

1. The Policy requires that certain approved persons successfully complete the compliance course within each three-year CE cycle. To determine which approved persons are required to take the course, please refer to the Policy itself.
2. A Member can choose to develop and deliver a compliance course, which reflects its own assessment of its current needs and priorities, or it may purchase a compliance course from an external provider. Alternatively, Members may offer a combination of both.
3. Compliance courses completed by branch managers, sales managers and others in a supervisory position should reflect their additional responsibilities.
4. The Member must maintain a record of successful completion of the compliance course.
5. As part of the audit process, IIROC  will review Member-developed compliance courses to ensure they satisfy the Guidelines.
6. If the compliance course program includes an examination, this examination must be successfully completed in order for the course to be applied towards the individual’s Compliance requirement.
7. Seminars that support other courses, or preparatory courses that support a course or examination, do not qualify separately for CE credit. The course or examination they support must be successfully completed in order to complete the CE requirement and the support or preparatory course hours may then be included in determining the duration of the total course.
8. A Participant who sits on a committee or council of IIROC, or who teaches a financial course may receive CE credits provided the member firm determines that the issues dealt with are relevant. The member firm may determine the amount of time applicable towards CE Compliance credits.

B. DELIVERY GUIDELINES

1. The course or courses used to fulfill the compliance requirement must be a minimum of 12 hours in total duration.
2. The Guidelines have been developed to offer some flexibility to Members and their approved persons. The manner in which the topics are reviewed is left to the Member’s discretion, provided the minimum 12-hour requirement for every 3-year cycle is satisfied.
3. The Member may choose to deliver the compliance course in a number of ways. The following are examples of possible modes of delivery, but is not exhaustive:
   
   
1. A Member may hold an 8-hour in-house compliance seminar, with 4 hours of preparatory reading and study. In the first part of the seminar, topic areas listed in C.(1)(a) to (d) below, could be reviewed. Then the information imparted could be used in the discussion of case studies during the remainder of the seminar, or
2. A Member could offer the compliance course over the three years, by requiring their approved persons to
   participate in a minimum 4-hour seminar every year. However, the seminar must still cover at least one of the 4 topic areas set out below and must do so in sufficient depth.
   
   
4. It is up to the Member to determine what constitutes successful completion of the course by its approved persons. For example, a Member may:
   
   
1. require its approved persons to write and pass a firm-developed and delivered exam,
2. require its approved persons to write and pass an external course provider developed and delivered exam, or
3. require a certificate of attendance and participation at a seminar.
   

The preceding list of examples is not exhaustive.

C. COURSE CONTENT

1. The course content must fall within at least one of the following 4 major topic areas:
   
1. Review of critical regulations and application
2. Regulatory changes
3. Rules relating to new products, if offered by the firm
4. Ethics
   
2. Some examples of relevant issues for the 4 topic areas are provided below. Examples are given for both institutional and retail registrants. Certain of the examples will change over time to reflect emerging issues in the industry
1. How the Securities Administrators and Self Regulatory Organizations Regulate Securities Industry Participants
2. Regulatory Developments that Affect Firm Management
3. Disclosure of Information to Clients
4. Registration and Continuing Education
5. Operations and Firm Capital
6. Sales and Trading Conduct – General
7. Sales and Trading – Institutional Markets
8. Current Developments in Bond Market Regulation
9. Suitability and New Products
10. Corporate Finance – New Rules
11. Corporate Finance – Proposed New Rules
12. Ethical issues and Case Studies
13. Anti-money laundering laws and regulations and their implementations at the Member.
    
3. The importance of certain topics may vary by Member, depending on the Member’s business and the participants’ individual responsibilities.
   

THE PROFESSIONAL DEVELOPMENT COURSE

A. BASIC PRINCIPLES

1. In general, the courses should be relevant to the securities industry and financial advisors, management-oriented, or designed to improve client service.
2. The subject matter of an individual’s course or courses should reasonably reflect that person’s skill requirements or be based on the firm’s products and market strategies.
3. The program undertaken should reflect the industry’s commitment to high quality client service, advice, and professionalism.
4. The subject matter should be educational and non-promotional in nature. For example, the following would not qualify: corporate events held exclusively to introduce or promote new product or service offerings, networking events, or motivational speakers.
5. The program’s provider should be professional, having defined the program’s learning outcomes in advance, and be able to certify a student’s successful completion. Alternatively, the firm may certify a student’s successful completion, and assume responsibility for this function.
6. If the course program includes an examination, this examination must be successfully completed in order for the course to be applied towards the individual’s Professional Development requirement.
7. Seminars that support other courses, or preparatory courses that support a course or examination, do not qualify separately for CE credit. The course or examination they support must be successfully completed in order to complete the CE requirement and the support or preparatory course hours may then be included in determining the duration of the total course.
8. An individual who teaches a relevant course may receive CE credits provided the member firm determines that the issues dealt with are relevant to Professional Development. The member firm may determine the amount of time applicable towards CE Professional Development credits.

B. DELIVERY GUIDELINES

1. The course, or combination of courses, used to fulfill the Professional Development course must be at least 30 hours.
2. The Guidelines have been developed to offer some flexibility to Members and their approved persons. The manner in which the topics are reviewed is left to the Member’s discretion, provided the minimum 30-hour requirement for every 3-year cycle is satisfied.
3. The determination of delivery should consider both the most appropriate learning tools and the need to ensure that requirements have been met. In different situations, any of the following may prove to be appropriate
   
   
1. Self-study materials which may contain an evaluation
2. Material delivered electronically through computer-based technology
3. Seminars and discussions delivered through internal or external providers
   
   
4. Material should, where possible, use cases and other application-based learning to develop problem-solving and decision-making skills. Training strategies should focus on product knowledge, regulatory knowledge, business development skills, managerial skills and client communication skills.
5. In some firms, programs have been developed beyond the basic licensing requirements for investment advisors, branch managers, and others. These courses are designed to develop additional skills particular to the position. This type of course would generally meet the criteria for the continuing education program. However, these courses must be of a non-promotional nature, i.e. there must be no specific product incentives attached.
   

C. COURSE CONTENT

1. Generally, the courses ought to examine products, services and investment and financial strategies that the individual may offer to clients or managerial skill for individuals. More specifically, the courses and materials should deal with the following areas:
   
   
1. Product features which should be fully communicated to a client in recommending a product
2. Approaches to valuation of a product and the product’s applicable risk factors
3. Strategies for investing in a product including the particular client objectives in which it would provide the most suitable results
4. The suitability of the use of leverage for a particular product and investment strategy
5. The features and applicable cost of a service which the firm offers
6. The regulatory, tax and other features of a product or service which might affect its suitability
7. Methods of evaluating competing products, services and investment strategies
8. The suitability of a product, service or strategy for clients with different financial, risk and knowledge profiles
9. Managerial skills which would assist managers in meeting strategic and operational objectives
10. Communication skills which would result in improved client service and determinations of client service
11. Practice management skills which would provide tools to assist firm personnel in improving client service
12. Technology used to enhance client service and the provision of advice.
    
    
2. The following are some examples of external courses that would likely fit the criteria outlined in the framework for an individual’s course of study:
   
   
1. Courses and seminars offered by the Canadian Securities Institute. Additional licensing courses such as derivatives courses may be used to satisfy the requirement; however, the Professional Financial Planning Course or Investment Management Techniques Course may be used only if it has not been used to satisfy the requirement of Policy 6, Part I, Section A.3(c).
2. Relevant courses offered or endorsed by professional associations that have licensing and continuing education programs such as, CIMA, CFP, CFA, IQPF, CLU and insurance licensing.
3. Relevant courses delivered through established post secondary institutions.
   

SUGGESTED PROCESS TO ESTABLISH TRAINING SOLUTIONS FOR MEETING CONTINUOUS EDUCATION REQUIREMENTS

1. Identify Training Needs
   
   
1. Identify knowledge and skills, which would impact positively on the firm and individuals.
2. Identify the learning objectives expected from the program or course.
   
   
2. Identify the evaluation method(s) to be used.
3. Determine how successful completion is to be ascertained.
4. Identify the delivery mechanism
   
   
1. Determine whether external or internal delivery is most appropriate approach.
2. Determine external suppliers or internal experts who are professional and capable of providing delivery of material.
3. Identify programs / courses that would deliver the skills and knowledge which would meet the firm and individual needs.
   
   
5. Cross-check outcomes desired against outcomes promised.