Terms and Conditions
Decision rendered on May 14, 2018
Beginning 7 days of the date of these Terms and Conditions, M Partners shall retain the consultant to:
a. oversee and assist M Partners with the implementation of the Program;
b. monitor M Partners' compliance with its regulatory obligations, internal policies and procedures, and the Terms and Conditions; and
c. report in writing to IIROC bi-monthly in respect of M Partners' implementation of the Program and compliance with its regulatory obligations, internal policies and procedures, and the Terms and Conditions.
Beginning 30 days of the date of these Terms and Conditions, M Partners shall provide to IIROC on a monthly basis:
a. copies of the monthly checklist of supervision over employee accounts held at other Dealer Members;
b. research report approval checklists and sign offs;
c. detailed evidence of enhanced supervision of employees subject to strict and close supervision, including supervision of outside accounts maintained by such employees; and
d. evidence of daily and monthly supervisory reviews using the issues log to track all investigation results, escalation, mitigations and action taken.
Within 30 days of these Terms and Conditions, M Partners shall provide to IIROC:
a. a complete list of all employee accounts held at other Dealer Members;
b. an up-to-date statement of conflicts of interest together with evidence of approval;
c. an up-to-date client relationship disclosure document together with evidence of approval; and ·
d. a complete list of OBAs for each employee, evidence of approval, and corresponding record from the National Registration Database for each registrant.
Within 90 days of these Terms and Conditions, M Partners shall provide evidence that an up-to-date client relationship disclosure document has been provided to all clients.
M Partners shall permit and facilitate requests by BCC staff for additional reporting, records and information relating to the Terms and Conditions.
M Partners shall authorize the consultant to permit unrestricted access by IIROC staff to the consultant regarding M Partners' progress with respect to any matter in relation to these terms and conditions. Items 1and 2 (a)- (d) of the Terms and Conditions shall remain in place for a minimum of six months from the effective date of this decision. At the conclusion of six months, if all of the Terms and Conditions have been satisfied, M Partners may apply to me to have Terms and Conditions modified or removed. I will consider whether removal or modification is appropriate, having regard to the information provided in the application, the consultant's reports, the recommendation of BCC staff, and such other information as I may require.