General Events to be Reported

SAFG shall report to the appropriate life insurance company:

  1. All client complaints in writing, against SAFG or a current or former Broker, relating to SAFG business;
  2. Whenever SAFG is aware, through a written or verbal complaint or otherwise, that SAFG or any current or former Broker has or may have contravened any law or regulatory requirements relating to:
  • Theft, fraud, misappropriation, forgery, money laundering, misrepresentation;
  • A breach of client confidentiality;

The KYC Form requires the Broker to obtain a considerable amount of information from the client. Brokers should be prepared to explain the significance of each of the questions on the Form. KYC updates should be completed every two years, at a minimum. The following list comprises the most common items from the forms and the significance of each item.

  1. Name & S.I.N.: The client’s full legal name and S.I.N. are required to properly identify the client, as well as to properly register accounts with Revenue Canada where necessary.
  2. Marital Status: This information allows the Broker to gain a better understanding of the financial resources available to the client. If the client is married and opens a joint account with their spouse, consistent KYC information is required from both parties (see Joint Accounts, section 5.3.4.).
  3. Permanent Address: Post office boxes and temporary addresses are not permitted (unless the client lives in a rural area) to ensure that the client is properly identified and to avoid disputes over the delivery of required documents, such as confirmations and statements. The Broker must obtain instructions in writing from the client before redirecting mail to another location or holding mail (see Hold Mail, section 8.2.6.1).
  4. Home & Business Telephone Numbers: Both home and business phone numbers are needed to verify identification and to contact the client immediately should a transaction or an account position warrant immediate contact.
  5. Date of Birth: Clients must be of the age of majority in the jurisdiction in which they reside in order to open an account. The client’s age is required to confirm he/she is of the age of majority as well as to complete a proper analysis of the clients retirement income needs.
  6. Client Occupation, Employer, and Type of Business: This information will assist the Broker in gaining a better understanding of the client’s personal and financial circumstances.
  7. Client Identification/Banking: Personally verified and recorded client identification and banking information is required in order to comply with the Money Laundering Terrorist Financing Legislation and to establish client identity and credit worthiness.
  8. Investment Knowledge: The client’s knowledge of investment matters provides the Broker with a measure of the degree of guidance that the client will require in working towards achieving his/her investment objectives. The Broker must balance the client’s knowledge with the investment products available, ensuring that the degree of risk the client assumes is consistent with their ability to assume this level of risk.
  9. Income & Net Worth: The client’s income and net worth information is required to demonstrate to regulatory authorities that the gathering of the KYC information is complete, as regulators invariably check KYC Forms for the existence of this information. It is also crucial information for taking the client through the financial planning process. In evaluating net worth, the Broker should only consider the paid-up portion of the client’s assets. The net worth and annual income figures may be an approximation or a range.
  10. Plan Type: Indicating the type of plan (i.e. Open, RRSP, LIRA, etc.) is important so that the KYC information relating to the type of plan, in the cases where the client has more than one type of plan, can be easily identified, reviewed and approved.
  11. Plan Owner: Indicating the owner of the plan (i.e. Individual, Tenants in Common, Joint with Rights of Survivorship, etc.) is important so that the KYC information relating to the type of plan, in the cases where the client has more than one type of plan, can be easily identified, reviewed and approved. This is also important in cases where the plan needs to be registered, to ensure it is registered properly. Furthermore, the Plan Owner is important for Joint plans to ensure all KYC information is obtained for both parties.
  12. Risk Tolerance: It is critical that clients fully understand and accept the risks they are undertaking with their investments. If there is any single piece of information that should most closely be scrutinized in relation to "suitability, this is it.
  13. Investment Objectives: Brokers, from discussions with the client, must determine and document the client’s investment objectives as clearly and precisely as possible. Clients who do not wish to provide their investment objectives could pose a greater degree of risk to both the Broker and to SAFG. Accordingly, the client should be advised that without the investment objectives, the Broker is not able to accept the account.
  14. Time Horizon: The length of time that the client expects the account to remain invested Short time horizons are generally require less volatility and risk, while long time horizons are able to withstand these factors in order to increase potential returns.
  15. Leverage: Leveraged investing is defined as borrowing money to finance an investment. There are a variety of lending programs available in the marketplace that can be utilized for investment purposes. These may or may not require the pledging of collateral such as the equity in one’s home or securities, including mutual funds. Although borrowing for RSP investment is typically viewed as a lower risk strategy than other leverage practices, it must still be regarded as leveraging to provide the required leverage disclosure to a client.