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, https://www.iiroc.ca/media/17141/download?inline

• Specifically:
  • there were 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 to The 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• A summary of the IIROC draft Guidance: "The Role of Compliance and Supervision | IIROC " which will be submitted to your firm's Board of Directors.
• The 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.