Exploring the connection between
rules, policies, and controls.

Lineage Atlas is a free research resource, open to anyone. It explores how regulatory requirements can inform the modelling and building of policies and controls, with a primary focus on monitoring and testing.

The catalogue breaks selected rules into plain-English obligations, with explanations and exact provision references. Use it to explore what a requirement means, how it might inform a policy or control, and what evidence could help assess whether that control is working.

The initial dataset covers selected provisions of CIRO Rule 3900. It is a starting point for the research; the project may explore other topics and regulatory sources as it develops.

Browse obligations

Rule 3900 · Part A

10 obligations

All records are editorial drafts
SUP-001Supervisory Systems

Establish a written supervisory system

Establish and maintain written supervisory policies and procedures for employees and Approved Persons that provide reasonable assurance of compliance with CIRO requirements, securities laws and other applicable laws.

§3904(1)§3904(2)(i)§3904(2)(ii)§3904(2)(iii)
SUP-003Policies and Procedures

Provide relevant policies to personnel

Provide sales and supervisory employees and Approved Persons with the sales-practices policies and procedures relevant to their functions.

§3904(3)(i)
SUP-004Records and Documentation

Obtain and record policy acknowledgements

Obtain and record acknowledgements from sales and supervisory employees and Approved Persons that they have read and understood the policies and procedures relevant to their roles and responsibilities.

§3904(3)(ii)
SUP-005Training and Communication

Educate Approved Persons and distribute compliance information

Provide introductory and continuing education to Approved Persons on relevant policies and changes; communicate applicable regulatory information to relevant sales employees and Approved Persons; and establish procedures for the method and timing of distributing compliance notices.

§3904(3)(iii)§3904(3)(iv)§3904(3)(v)
SUP-006Training and Communication

Communicate policy changes and clarify responsibilities

Promptly communicate policy and procedure changes to relevant employees and Approved Persons, and maintain procedures that provide reasonable assurance they understand their responsibilities.

§3904(3)(vi)§3904(3)(vii)
SUP-008Personnel and Qualifications

Appoint sufficient qualified Supervisors and Executives

Appoint enough Supervisors to supervise employees and Approved Persons, and designate enough Executives to support compliance, taking account of the firm’s scope and complexity; ensure those designated have the qualifications and authority needed for their assigned duties.

§3905(2)§3905(3)§3905(4)
SUP-009Personnel and Qualifications

Ensure supervisory personnel understand supervised activities

Take reasonable steps to ensure Supervisors and Executives are sufficiently proficient and understand the products traded or advised on and services provided by the personnel they supervise, to the degree necessary for proper supervision.

§3905(5)