The Investment Industry Regulatory Organization of Canada (IIROC) has issued new guidance for firms on supervising employees who work from home as the investment advisor workforce becomes increasingly mobile and flexible.
IIROC is increasingly seeing advisors who work from home through remote technology. In response to the trend, the self-regulatory organization (SROs) has issued the notice, “to clarify our approach and expectations” for these working arrangements.
In particular, IIROC reports that its registration and business conduct compliance (BCC) departments have been reviewing the SRO’s approach to “work-from-home” (WFH) arrangements and business locations.
“Our compliance approach to [WFH] arrangements will in part be based on the dealer member’s compliance record,” IIROC’s guidance states, “if it suggests that the dealer member may not adequately oversee WFH arrangements.”
Dealers should maintain an updated list of the advisors who regularly work from home, which the BCC department could use as it plans compliance exams, IIROC’s notice says.
The guidance also sets out the factors that dealers should consider in determining whether a residence needs to be formally reported to IIROC as a business location.
“We support taking a flexible approach to WFH arrangements to reflect the importance of IIROC having notice of such arrangements and the authority to take regulatory action in relation to locations where registerable activity takes place,” the SRO’s notice says, “without imposing an undue regulatory burden.”
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