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Scenario: Your team, Compliance - Projects and Initiatives, reports to the head of Wealth Management Compliance for a large Canadian Bank. Your team's role within

Scenario:

Your team, "Compliance - Projects and Initiatives", reports to the head of Wealth Management Compliance for a large Canadian Bank.

Your team's role within the Wealth Management Compliance includes:

  • Responsibility for leading and managing a team of senior compliance professionals.
  • Managing firm-wide projects and initiatives for Wealth Management Compliance in response to regulatory developments and bank initiatives.
  • Working with senior management to help ensure various Compliance areas meet their mandates and yearly and quarterly objectives and targets.
  • Coordinating development, review and completion of Wealth Management.
  • Compliance policies and procedures, and ensuring that a consistent approach, structure and quality are applied with firm-wide policies and procedures.

During a recent IIROC Audit, it was revealed that there were some reporting deficiencies relating to the CCO and Board of Directors as outlined in 3915: Report to Dealer Member's board of directors: Link:Report to Dealer Member's board of directors | IIROC

  • Specifically:
    • there was insufficient personnel and other resources to fully and properly enforce the written policies and procedures required by IIROC rule 3904Policies and procedures | IIROC
    • it was noted that the CCO did not provide reports to the Board of Directors as required by IIROC rule 3915 Report to Dealer Member's board of directors | IIROC
    • a lack of a governance document setting out the organizational structure and reporting relationships of IIROC Rule 3916:Governance document | IIROC
  • IIROC has submitted a Guidance Notice relating toThe Role of Compliance and Supervision | IIROC

Required:

You have been asked by your boss to submit a report outlining:

  • A summary of the IIROC draft Guidance: "The Role of Compliance and Supervision | IIROC " which will be submitted to your firm's Board of Directors.
  • Step you would take as the Director of the Projects and Initiatives team to address the noted deficiencies above.
  • As part of your summary, you are required to provide a recommended reporting structure for the CCO to the Board of Directors.

Items to consider:

Assume the Board of Directors has limited information on "The Role of Compliance and Supervision", as a result, clear, concise and plain language will be needed.

Assumptions about the firm, your department and the issues identified in the audit report should be clearly outlined at the beginning of this section of the report.

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