Educate Approved Persons and distribute compliance information

Understanding the obligation

Rule 3904(3)(iii) requires introductory and continuing education for all Approved Persons concerning the dealer's policies and procedures and relevant changes. Subsection (3)(iv) separately requires communicating relevant information about CIRO requirements and applicable laws to sales employees and other Approved Persons.

Subsection (3)(v) adds a procedural requirement: the firm must address how and when compliance-related notices are distributed. These connected duties concern training, regulatory communication and the delivery of compliance notices. They do not prescribe a single course format or training platform.

Requirements

• Provide introductory education on the firm's policies and procedures to all Approved Persons.
• Provide continuing education to Approved Persons, including relevant policy changes.
• Communicate relevant CIRO requirements and applicable-law information to covered sales employees and other Approved Persons.
• Maintain policies and procedures specifying the method and timing of compliance-notice distribution.

Practical considerations Illustrative

Implementation examples, rather than additional express requirements.

• Differentiate onboarding education from ongoing updates.
• Target communications by role so that material reaches personnel to whom it is relevant.
• Define the notice channels and expected distribution timing in a written process.

Potential evidence Illustrative

Examples of evidence; the cited provisions may not mandate these records.

• Onboarding and continuing-education materials
• Training participation or completion records
• Compliance notices and distribution records
• Written procedures for notice distribution