Compliance Memo

CM_2022-02; Postponement of new IPQ Requirement

For more information, contact:

Compliance Team

Date Issued:

January 28, 2022

This is an update to the Compliance Memo 2021-05 dated December 30, 2021, regarding the requirement to obtain an IPQ as part of the KYC process for every NAAF or KYC update (where no IPQ has previously been completed).

This requirement was to come into effect as of February 1, 2022. We are updating the IPQ to a digital version, which will make the process much easier and efficient for you and your clients. The development of the digital version has been delayed, and we have therefore decided to move the effective date to March 1, 2022, for this policy change.

In the meantime, the current IPQ policy remains in place, and we strongly encourage you to obtain an IPQ with every client meeting you are conducting. It is a good practice which strongly enhances and supports your KYC suitability requirements.

As always, if you have questions or comments, contact the Compliance Department by email at