Obligations
Client files must contain information that demonstrates the suitability of the sale. Some key items your files must contain are:
Client consent to collect, use and disclose personal information
Fact find and needs analysis
Disclosure of advisor information signed by policy owner
Recommendations
Investment risk tolerance assessments for investment products or universal life insurance policies
Illustrations and sales aids presented to and discussed with clients
Records of client contacts/correspondence (includes a log of telephone contact and failed attempts, meeting summaries, emails, letters, faxes, etc.)
Copies of correspondence (from the advisor, client, etc.)
Forms/confirmations to support various transactions or requests
Specific to Quebec client files:
Fact find acknowledgment receipt provided to the client no later than the date the policy is delivered
Policy delivery receipt and illustration signed by client
Copies of applications for insurance (including medical and lifestyle information) and savings and/or income investment products
Confirmation of client’s decision (for all types of sales) – if applicable
Copy of replacement form with proof of sending
Financial planner files: Mandate and report from the financial planner – if applicable
Group insurance files: Mandate letter – if applicable
Registrant Governance and Compliance Guide