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.
Understanding the obligation
Rule 3904(3)(ii) requires a Dealer Member to 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 respective roles and responsibilities.
This is more specific than making a manual available or sending a distribution notice. The acknowledgement relates to both reading and understanding role-relevant material. The provision does not mandate a particular technology, electronic signature method, or universal renewal frequency; those details should not be presented as express CIRO requirements under this subsection.
Requirements
- Obtain acknowledgements from covered sales and supervisory employees and Approved Persons.
- Ensure the acknowledgement addresses reading and understanding relevant policies and procedures.
- Record the acknowledgements.
Practical considerations Illustrative
Implementation examples, rather than additional express requirements.
- Connect each acknowledgement to an identifiable person and the relevant policy set.
- Consider recording policy versions to reduce ambiguity when policies are revised.
- Provide a follow-up process for missing acknowledgements and a route for personnel to raise questions.
Potential evidence Illustrative
Examples of evidence; the cited provisions may not mandate these records.
- Recorded individual acknowledgements
- Associated policy versions or document identifiers
- Acknowledgement completion reports
- Follow-up correspondence for outstanding acknowledgements