Compliance Memo

CM_2023-02; Expired KYC Client Notification

For more information, contact:

Compliance Team

Date Issued:

January 13, 2023

As you know, it is a regulatory requirement to update KYCs no less frequently than once every 36 months (Rule 2.2.1). If this is not done, then the KYC is considered to be expired, and the account(s) is frozen to any further transactions, with the exception of redemptions.

It is not acceptable to have KYCs in expired status with no effort to update them in a timely manner. We recognize that in some cases, you may not be able to reach a client, or the client is non-responsive. In these instances, it is very important to document your efforts to contact the client(s) to update their KYC information. For all other cases, your obligation is to update KYC information within every 36-month cycle.

At present, there are a number of KYCs that are expired, and we must notify the affected clients in writing. In this connection, we will be sending a letter to each client whose KYC information has expired. This letter will be sent out on March 15, 2023. The clients will be given your contact information and encouraged to contact you to get their KYC information updated.

Please click here for a copy of the letter.

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