The Ontario Securities Commission (OSC) issued orders Thursday clarifying the conditions it imposed on the registrations of a couple of scholarship plan dealers earlier this year.

Back in August, the OSC issued orders requiring a pair of dealers ( Knowledge First Financial Inc. (KFFI) and Heritage Education Funds Inc. (HEFI)) to improve their compliance systems, following compliance reviews that were carried out earlier this year. The firms consented to the orders.

As a result, the firms are subject to several conditions, including the obligation to hire a monitor to scrutinize new accounts to ensure they comply with regulatory requirements.

According to the orders published Thursday, both firms have hired Deloitte & Touche LLP as their monitor, and have since sought direction from the commission on the scope of its work.

The orders released Thursday specify that Deloitte is only required to follow up with new clients, whose applications are missing information, or give rise to suitability concerns. And, the orders specify that those calls to clients don’t require Deloitte to ask new Know Your Client (KYC) questions, or impose new suitability criteria; although it can ask for income details in certain cases; it may take into account any information volunteered by the client; and, it may ask questions if necessary to resolve an inconsistency between the information on the original application and the information given to the monitor.

Also, in its reports to the commission, Deloitte is to detail the number of calls it has made, the number of applications accepted and rejected and the reasons for any rejections. The firm may also report on any deficiencies, potential deficiencies or concerns, but it is not required to provide any conclusions or recommendations with respect to KYC or suitability issues.