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.
Understanding the obligation
Rule 3904(3)(vi) requires prompt communication of changes to the dealer's policies and procedures to relevant employees and Approved Persons. Subsection (3)(vii) goes further: the dealer must have procedures providing reasonable assurance that each employee and Approved Person understands their responsibilities under those policies and procedures.
Communication and understanding are different objectives. A message announcing a policy update may establish that information was sent, but the dealer must also consider whether its procedures reasonably support personnel understanding of the responsibilities relevant to their work.
Requirements
- Promptly communicate changes to policies and procedures to relevant employees and Approved Persons.
- Maintain procedures designed to provide reasonable assurance that each employee and Approved Person understands their policy responsibilities.
Practical considerations Illustrative
Implementation examples, rather than additional express requirements.
- Identify who is affected by each policy change rather than relying exclusively on blanket announcements.
- Use briefings, questions, targeted education or other methods appropriate to the significance of the change.
- Consider how the firm identifies and addresses recurring misunderstandings.
Potential evidence Illustrative
Examples of evidence; the cited provisions may not mandate these records.
- Policy change notices and recipient lists
- Training or briefing materials for material changes
- Records of knowledge checks or follow-up questions, where used
- Procedures describing how understanding is supported