Provide relevant policies to personnel
Provide sales and supervisory employees and Approved Persons with the sales-practices policies and procedures relevant to their functions.
Understanding the obligation
Rule 3904(3) requires a Dealer Member to communicate policies and procedures to relevant employees and Approved Persons. More specifically, subsection (3)(i) addresses the provision of sales-practices policies and procedures to sales and supervisory personnel and Approved Persons whose functions make those materials relevant.
The emphasis is on role relevance. Distributing every document to everyone may be administratively simple, but does not itself establish that the right personnel have received the policies that govern their work. This distribution requirement is related to, but distinct from, the acknowledgement requirement in subsection (3)(ii).
Requirements
- Communicate policies and procedures to relevant employees and Approved Persons.
- Provide sales-practices policies and procedures to covered sales and supervisory personnel.
- Ensure the materials provided are relevant to recipients' functions.
Practical considerations Illustrative
Implementation examples, rather than additional express requirements.
- Organize policies by role, function or business line so recipients can find applicable requirements.
- Maintain an accessible current version and avoid leaving obsolete versions as the default reference.
- Coordinate distribution with acknowledgement and training processes without treating those separate duties as interchangeable.
Potential evidence Illustrative
Examples of evidence; the cited provisions may not mandate these records.
- Policy distribution lists or role-based access records
- Policy publication notices
- Current policy library with version identifiers
- Distribution or delivery records