Internal Investigation Procedures

SAFG’s compliance regime includes the performance of rotational Broker/Agency meetings. These meetings are necessary to ensure that all Brokers operate at a consistently high level of compliance. These meetings would/could include completion of a CLH 1A Standardized MGA Compliance Review Survey (Refer to Appendix) to:

• Assess compliance with applicable legislation;
• Assess compliance with the policies set out in the Compliance Manual and other corporate policies, as applicable;
• Assess the sales and market practices of Brokers;
• Allow SAFG to fulfill its statutory obligations regarding supervision.

Review of Marketing’s compliance issues:

• Review a sample of a minimum of 10 client files for the following:
• Suitability of client portfolios
• Current Know-Your-Client information
• General organization of files
• Documentation of client conversations/instructions
• Review of correspondence and other evidence for unusual or unethical activity:
• Direct discussions with insurance companies regarding co-operative marketing
• Review of advertising/sales communications

Interview of Broker and discuss the nature of their practice, covering such areas as:

• Client prospecting
• Marketing
• Complaints received/recent issues resolved or outstanding
• Products/services offered other than mutual funds
• Look for evidence of problems and/or non-compliance