Canadian Investment Funds Course - Regulatory Environment PDF

Canadian Investment Funds Course Unit 1: Regulatory Environment Introduction In Canada, there are a number of regulatory bodies and regulations that govern the sale of mutual funds. As a Dealing Representative, you need to be aware of these bodies and the regulations. Once you are licensed, your mut...

Canadian Investment Funds Course Unit 1: Regulatory Environment Introduction In Canada, there are a number of regulatory bodies and regulations that govern the sale of mutual funds. As a Dealing Representative, you need to be aware of these bodies and the regulations. Once you are licensed, your mutual fund dealer will provide further training about your responsibilities. This unit takes approximately 35 minutes to complete. Lessons in this unit: Lesson 1: Regulatory Bodies Lesson 2: Legislation and Regulations © 2021 IFSE Institute 7 Unit 1: Regulatory Environment Lesson 1: Regulatory Bodies Introduction The sale of mutual funds in Canada is regulated and monitored by a number of provincial and federal organizations. As a Dealing Representative, you need to be aware of the organizations and regulations that affect you in the province in which you are selling mutual funds. This lesson provides an introduction to the regulatory bodies. Your Compliance Department will provide more detailed training in your responsibilities. This lesson takes approximately 15 minutes to complete. By the end of this lesson, you will be able to: explain how the securities regulation is structured in Canada explain the role of each regulatory body: - Provincial securities commissions Canadian Securities Administrators (CSA) Mutual Fund Dealers Association of Canada (MFDA) Autorité de marchés financiers (AMF) Chambre de la sécurité financière (CSF) Investment Industry Regulatory Organization of Canada (IIROC) Ombudsman for Banking Services and Investments (OBSI) Office of the Superintendent of Financial Institutions Canada (OSFI) list the legislation that regulates the securities industry 8 © 2021 IFSE Institute Canadian Investment Funds Course Financial Services Regulatory Bodies When you become a Dealing Representative, you will be part of a group of professionals that needs to adhere to regulations designed to protect the interests of both the investing public and industry participants. In Canada, there are several monitoring bodies in the mutual funds industry at the provincial and national level. Provincial and Territorial Level Each province and territory has a regulatory body, usually referred to as a securities commission. National Level The following organizations all play a role in the regulation of the Mutual Funds industry: Canadian Securities Administrators (CSA) Mutual Fund Dealers Association of Canada (MFDA) Ombudsman for Banking Services and Investments (OBSI) Investment Industry Regulatory Organization of Canada (IIROC) Office of the Superintendent of Financial Institutions Canada (OSFI) Securities Regulators Mandate All provinces and territories have a regulatory body (Securities Regulator), often referred to as a securities commission, which administers that jurisdiction's Securities Act or equivalent legislation. Each Securities Regulator sets its own standards for registration and has the power to grant or revoke registrations. Securities Regulators generally have a mandate to: protect investors from unfair, improper and fraudulent practices promote fair and efficient capital markets promote confidence in capital markets reduce systemic risk For registered firms and individuals that are directly regulated by the provincial and territorial securities regulators, the rules, regulations, and legislation apply specifically to securities, and are not extended to © 2021 IFSE Institute 9 Unit 1: Regulatory Environment related investment products. This differs from the regulatory requirements for registered firms who are regulated by the self-regulatory organizations (SROs). SRO-regulated firms include investment dealers, who are members of the Investment Industry Regulatory Organization of Canada (IIROC), and mutual fund dealers, who are members of the Mutual Fund Dealers Association of Canada (MFDA). SRO member firms and their Dealing Representatives are subject to rules and regulations that apply to securities and related investment products, including structured products. For the purposes of this course, the terms “securities” and “investment products” are used interchangeably, though both apply to mutual fund dealers and their Dealing Representatives. Securities Regulator/Securities Commission Role Each Securities Regulator is responsible for the following: establishing strict standards for disclosure of information before new securities can be offered to the public reviewing and approving mutual funds and new issue prospectuses before they are offered for sale in their province or territory registering the companies and individuals who sell securities in their province or territory registering the companies and individuals that manage mutual fund portfolios established in their province or territory enforcing securities regulations governing the buying and selling of securities investigating investor complaints against companies and their employees disciplining companies or individuals found to contravene the regulations Your role as a Dealing Representative is to: register with your Securities Regulator adhere to the Securities Regulator's rules, regulations and standards Canadian Securities Administrators (CSA) The CSA is a policy-making body composed of members from each Securities Regulator. It is a forum for Canada's Securities Regulators to improve, coordinate, and harmonize regulation of the Canadian capital markets. 10 © 2021 IFSE Institute Canadian Investment Funds Course The CSA’s mandate consists of three goals: to protect investors from unfair, improper, or fraudulent practices to foster fair and efficient capital markets to reduce risks to the market’s integrity, and to investor confidence in the markets CSA pursues these goals through a national system of harmonized securities regulations, policies, and practices. Securities Regulators enforce these regulations, policies and practices. Mutual Fund Dealers Association of Canada (MFDA) The Mutual Fund Dealers Association of Canada (MFDA) is the self-regulatory organization for the distribution side of the Canadian mutual funds industry. The MFDA is structured as a not-for-profit corporation and its members are mutual fund dealers that are licensed with Securities Regulators. All mutual fund dealers outside the province of Québec are required to be members of the MFDA. As a self-regulatory organization, the MFDA is responsible for regulating the operations, standards of practice and business conduct of its members and their Dealing Representatives, with a view to enhancing investor protection and strengthening public confidence in the Canadian mutual fund industry. The MFDA is empowered by securities regulators in each of the enumerated jurisdictions (provinces and territories) to: admit members perform compliance reviews enforce rules through a transparent disciplinary process that can result in fines, suspension, or termination of membership The MFDA also administers a separate legal entity called the MFDA Investor Protection Corporation (IPC) that provides protection for eligible customer losses as a result of a MFDA Member's insolvency. The IPC is funded by contributions from MFDA Members and provides customers with coverage to a maximum of $1 million in their general accounts and a maximum of $1 million for their retirement accounts. This coverage only extends to accounts held by MFDA Members in nominee name, and the coverage does not apply to funds held in client name at fund companies. Ombudsman for Banking Services and Investments (OBSI) The Ombudsman for Banking Services and Investments (OBSI) is not a regulator but an independent and impartial organization whose objective is to attempt to resolve disputes between participating banking services and investment firms and their clients. As of August 1, 2014, all dealers and advisors must also be © 2021 IFSE Institute 11 Unit 1: Regulatory Environment OBSI members, except in Quebec where the mediation regime administered by the AMF will continue to apply. OBSI can provide recommendation to settle claims up to $350,000. As an alternative to the legal system, OBSI provides a mechanism to ensure members deal fairly with their customers. Securities Regulatory Bodies in Quebec In Quebec, there are two monitoring bodies. Autorité de marchés financiers (AMF) Mutual fund dealers operating in the province of Québec are required to be registered under the Autorité de marchés financiers (AMF), the securities regulator in Québec. The AMF has further delegated the responsibility of ongoing regulatory compliance and continuing education requirements to the Chambre de la sécurité financière (CSF). Chambre de la sécurité financière (CSF) The Chambre de la sécurité financière (CSF) is the recognized self-regulatory organization (SRO) for Québec representatives dealing in investment funds that are not under IIROC supervision. (In Québec, IIROC is the recognized SRO for investment dealers.) CSF's mission is to protect consumers by maintaining discipline and overseeing the training and ethics of its members, which include Dealing Representatives and financial planners. Note: Quebec is the only province where registration for financial planning activities is required. The CSF is empowered by the AMF in Québec to: admit members investigate complaints enforce rules through a disciplinary process that can result in fines, suspension or termination of membership Investment Industry Regulatory Organization of Canada (IIROC) The Investment Industry Regulatory Organization of Canada (IIROC) is the national self-regulatory organization for investment dealers. IIROC’s principal activities include: protection of the investing public self-regulation 12 © 2021 IFSE Institute Canadian Investment Funds Course liaison with provincial securities commissions public policy representation maintenance of orderly marketing and trading education publication of statistical information liaison with other financial institutions IIROC’s main objective is to create a favourable environment for the investing public by encouraging high practice standards and enforcing regulatory compliance in its membership. Office of the Superintendent of Financial Institutions (OSFI) The Office of the Superintendent of Financial Institutions Canada (OSFI) is the primary supervisor and regulator of insurance companies, federally regulated deposit-taking institutions, and federally regulated private pension plans. OSFI does not regulate mutual fund and investment dealers. OSFI’s mandate is to: protect the rights and interests of depositors, policyholders, pension plan members and creditors of financial institutions contribute to public confidence in the Canadian financial system Mutual Fund Legislation The mutual fund industry is mainly regulated through the following: The Securities Acts National Instruments developed through the CSA MFDA Rules This section provides an overview of the legislation that regulates mutual fund dealers. Individual firms are required to interpret the regulations and prepare policies and procedures for Dealing Representatives to follow. Mutual funds are securities and are therefore governed by the Securities Acts, which are extensive pieces of legislation that cover the entire field of securities. The Securities Acts contain important provisions regarding mutual funds. © 2021 IFSE Institute 13 Unit 1: Regulatory Environment The responsibility for administering and enforcing the Securities Act in each jurisdiction rests with the Securities Regulator. National Instruments National instruments are harmonized regulations made by the Securities Regulators through the CSA. The main instruments affecting mutual funds are: NI 31-103 – Registration Requirements and Exemptions NI 81-101 – Mutual Fund Prospectus Disclosure NI 81-102 – Mutual Funds NI 81-105 – Mutual Fund Sales Practices National Instruments NI 31-103 NI 31-103 Registration Requirements and Exemptions provides the harmonized registration rules for the registration of firms and individuals with the provincial or territorial securities commissions. NI 81-101 NI 81-101 Mutual Fund Prospectus Disclosure ensures that mutual funds disclose the information that investors should consider when deciding whether to invest, or remain invested, in a fund. It prescribes the content of key disclosure documents including the simplified prospectus, the Fund Facts and the annual information form. NI 81-102 NI 81-102 Mutual Funds is the main instrument regulating mutual funds. It regulates how mutual funds are managed, bought and sold. NI 81-105 NI 81-105 Mutual Fund Sales Practices ensures that mutual funds are sold on the basis of what is suitable for, and in the best interests of, investors. It sets minimum standards of conduct to be followed by managers, principal distributors, registered dealers and Dealing Representatives when distributing mutual funds. MFDA Rules The MFDA regulates the operations, standards of practice, and business conduct of its members in order to protect investors. 14 © 2021 IFSE Institute Canadian Investment Funds Course MFDA Rules set out detailed requirements for members, including particulars regarding: business structures capital requirements insurance books and records client reporting business conduct supervision suitability and trade review The MFDA also regulates Dealing Representatives by virtue of their relationship with their sponsoring mutual fund dealer. © 2021 IFSE Institute 15 Unit 1: Regulatory Environment Lesson 2: Legislation and Regulations Introduction As a Dealing Representative, you need to be aware of other important regulations that affect you. These include Anti Money Laundering (AML), Privacy (PIPEDA), and the Do Not Call List (DNCL). These regulations affect how you interact with your customers, the type of information you collect, and certain reporting responsibilities. This lesson provides an overview of the regulations. The Compliance Department of your mutual fund dealer will provide more information about your responsibilities. This lesson takes approximately 20 minutes to complete. By the end of this lesson, you will be able to: explain the purpose of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) discuss the role of Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) describe the Dealing Representative’s obligations under the PCMLTFA explain how the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA) safeguard privacy define what qualifies as personal information under PIPEDA explain the requirements under the Do Not Call List (DNCL) explain the requirements under the Canada’s Anti-Spam Law (CASL) explain the requirements under the United States (US) Foreign Account Tax Compliance Act (FATCA) 16 © 2021 IFSE Institute Canadian Investment Funds Course Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) is an Act to combat the laundering of proceeds of crime and the financing of terrorist activities1. This legislation was introduced to: help detect and deter money laundering and terrorist financing activities provide law enforcement officials with tools to investigate and prosecute money laundering or terrorist financing offences respond to Canada's international commitments to participate in the fight against multinational crime The Act implements reporting and other requirements for entities susceptible to being used for money laundering or terrorist financing. This includes financial entities, life insurers, money service businesses, those involved in real estate, securities dealers, dealers in precious metals and stones, and casinos. Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada’s financial intelligence unit. It collects, analyzes, and discloses information to help detect and prevent money laundering and the financing of terrorist activities in Canada and abroad. FINTRAC’s mission is to contribute to the public safety and help protect the integrity of Canada's financial system by detecting and deterring money laundering and terrorist financing. Under Canadian law, money laundering is any act intended to disguise the source of money or assets derived from criminal activity inside or outside Canada. The dirty money produced through criminal activity is transformed into clean money by making its criminal origin difficult to trace and integrating it into the legitimate economy. Once illegal money has entered the financial system and is held in cash accounts with financial institutions, a common money laundering method is to use it to purchase securities. Terrorist financing provides funds for terrorist activity. Terrorist groups must develop sources of funding and ways to obscure the links between those sources and the activities the funds support. 1 Revised requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing legislation, regulations, and FINTRAC Guidelines came into force June 2020. The new requirements will be reflected in the next version of the course. For exam purposes, the content in this version of the course will apply. © 2021 IFSE Institute 17 Unit 1: Regulatory Environment There are two primary sources of financing for terrorist activities: countries, organizations, or individuals revenue-generating activities The methods terrorist groups use to generate funds from illegal sources often resemble those used by traditional criminal organizations. Like criminal organizations, terrorist groups need to find ways to launder these illicit funds to be able to use them without attracting the attention of the authorities. Your Role As a Dealing Representative you have four key areas of responsibility under the PCMLTFA. These areas are: reporting to FINTRAC record-keeping confirming your client’s identity identifying politically exposed foreign persons Your mutual fund dealer’s Compliance Department will provide more training and guidance in these areas. Reporting to FINTRAC As a Dealing Representative, you must advise your dealer of completed and attempted suspicious transactions and certain other financial transactions. Your dealer must report these suspicious transactions to FINTRAC. FINTRAC publishes guidelines for when to file reports and offers instructions for how to file them. Record-keeping Securities dealers, portfolio managers and investment counsellors must keep the following records: Large cash transaction records - cash transactions of $10,000 or more Account-related records - account opening records and client statements Other records - other records designated by your Compliance Department such as records of suspicious transaction reports Records must be kept in such a way that they can be provided to FINTRAC within 30 days of a request to examine them. 18 © 2021 IFSE Institute Canadian Investment Funds Course Confirming Your Client’s Identity You and your employer have to confirm your client’s identity in the following circumstances: when opening a non-registered account when a client conducts a large cash transaction if you do not recognize the client when a client conducts or attempts to conduct a suspicious transaction when an individual is authorized to give instructions for an account about which you have to keep a record An individual may be identified by means of his or her birth certificate, driver's license, passport, record of landing, permanent resident card, social insurance number, old age security card, certificate of Indian status, provincial identification card or similar document. The documents may be Canadian or foreign equivalents. Note: Health Cards from Ontario, Manitoba and PEI are not allowed to be used for identification purposes. In Québec, you are not allowed to ask to see a client’s health card, but you may accept it if the client volunteers to use it for identification purposes. If you are unable to identify an individual at the time of opening an account you may accept an initial deposit, but may not carry out any further transactions until the client has been properly identified. If a client is evasive or unwilling to provide sufficient information for adequate identification, you must inform your Compliance Department. Identifying Politically Exposed Foreign Persons Individuals are considered politically exposed foreign persons2 if they or any of their immediate family hold or held any of these positions in a foreign country: head of state or government member of the executive council of government or legislature deputy minister (or equivalent) ambassador or ambassador’s attaché or counsellor military general (or higher rank) president of a state-owned company or bank head of a government agency 2 Changes to the identification requirements came into force June 2020 to include Politically Exposed Persons (PEPs), both foreign and domestic, and the Heads of International Organizations (HIOs). Changes will be reflected in the next version of the course. For exam purposes, the content in this version of the course will apply. © 2021 IFSE Institute 19 Unit 1: Regulatory Environment judge leader or president of a political party in a legislature Privacy Legislation Collecting Personal Information In your role as a Dealing Representative, it is your duty to collect personal information from your client. You have an obligation to keep that information confidential. The collection, use, and disclosure of an individual's personal information are protected by legislation. To protect personal information, the Federal Government has the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA). Other provincial privacy acts may provide additional protection for personal information. Privacy Act This law imposes obligations on federal government departments and agencies to respect privacy rights by limiting the collection, use, and disclosure of personal information. The Privacy Act also gives individuals the right to access any personal information about themselves that these organizations hold and request correction if necessary. Personal Information Protection and Electronic Documents Act (PIPEDA) PIPEDA is Canada's private sector privacy law. PIPEDA establishes rules for how federally regulated private sector organizations may collect, use, or disclose personal information. PIPEDA does not apply in provinces that have enacted similar legislation (Québec, Alberta, and British Columbia). Even where provincial legislation has been enacted, organizations' sharing of personal information across provincial, territorial, or international borders is governed by PIPEDA. PIPEDA has rules for safeguarding the personal information that you collect about your clients. Personal information must be: collected for a reasonable purpose collected with an individual's consent used and disclosed for the purpose for which it was collected accurate accessible for inspection and correction stored securely 20 © 2021 IFSE Institute Canadian Investment Funds Course PIPEDA does not apply to: any government institution to which the Privacy Act applies someone who collects, uses, or discloses personal information strictly for personal purposes (for example, the collection of names and addresses for a wedding invitation list) an organization that collects, uses, or discloses personal information for journalistic, artistic, or literary purposes and does not do so for any other purpose Other Provincial Privacy Acts Alberta, British Columbia, Québec and Ontario (only with respect to personal health information held by health information custodians) have privacy laws which have been recognized by the Federal Government as substantially similar to PIPEDA. When operating within one of those jurisdictions, organizations are subject to the provincial privacy legislation instead of PIPEDA, and to the authority of the provincial privacy commissioner. What is Personal Information PIPEDA has rules governing what private sector organizations can do with "personal information". The definition of "personal information" under the Act is any factual or subjective information, recorded or not, about an identifiable individual. Personal information includes: age, weight, height, name where it appears with other personal information medical records ID numbers, income, ethnic origin, blood type opinions, evaluations, comments, social status, disciplinary action employee files, credit records, loan records, dispute with a merchant, intentions (for example, to acquire goods or services, or change jobs) It does not include: an employee's name, title, business address or telephone number (such as information on a business card) © 2021 IFSE Institute 21 Unit 1: Regulatory Environment Do Not Call List (DNCL) The Canadian Radio-television and Telecommunications Commission (CRTC) has established a National Do Not Call List (DNCL) as part of its Unsolicited Telecommunications Rules. The intention of the DNCL was to give consumers the choice about whether to receive telemarketing calls or not. Telemarketing refers to unsolicited telecommunications to sell or promote a product or service. If a person has registered a phone number on the DNCL, you are not permitted to call that person for telemarketing purposes if they have not given you express permission to do so. This prohibits you from coldcalling a possible new client, as well as former clients who have not done business with you in the last 18 months who are registered on the DNCL. You are also prohibited from cold-calling former clients who have done business with you in the last 18 months who are registered on the dealer’s own do not call list. You are permitted to call your existing clients or your dealer’s clients. Depending on your relationship, the client would expect to be contacted regarding investment advice, changing market conditions, or even due to regulatory requirements. Canada's Anti-Spam Legislation (CASL) In an effort to protect consumers from unwanted electronic messages, the Government of Canada introduced legislation to deal with unsolicited commercial electronic messages, also referred to as spam. Under the Electronic Commerce Protection Act (ECPA), senders of commercial electronic messages must obtain consent from the recipient before a message is sent. Senders must also identify themselves and allow the recipient to withdraw consent. CASL is designed to regulate the transmission of commercial electronic messages (CEMs). In addition to CEMs, CASL deals with other electronic threats to commerce, such as malware, spyware, pretexting, and the harvesting of electronic address and personal information. What is a commercial electronic message? The concept of a commercial electronic message (CEM) is central to CASL. CEMs are essentially emails or other electronic messages that that contain commercial or promotional information to encourage participation in a commercial activity. CEMs also include electronic messages that contain a request for consent to send such messages. CASL prohibits organizations from sending CEMs to consumers unless all of the following conditions are met: the recipient has consented to receive the message the message includes information that identifies the sender the message enables the recipient to withdraw consent and unsubscribe from all future messages 22 © 2021 IFSE Institute Canadian Investment Funds Course While organizations are permitted to provide consumers with the option to unsubscribe from only certain types of messages, they must also provide consumers with the option to unsubscribe from all future messages. Summarized below is an overview of CASL requirements. Overview of CASL Requirements Recipient must Opt In Recipients must positively opt in to receiving CEMs from the organization Organizations cannot send CEMs to recipients who have not consented to receive the CEMs by opting in Recipient Consent The recipient’s consent to receive CEMs may be express or implied Pre-checked boxes cannot be used to obtain express consent Recipients must take some positive action to indicate consent, such as checking a blank box Penalties The CRTC has the authority to impose administrative monetary penalties for violations of CASL: Maximum penalty for individuals: $1 million Maximum penalty for organizations $10 million Possible damages and statutory damages for businesses Possible liability for directors and officers As a Dealing Representative, it is important for you to familiarize your dealer’s policies and procedures regarding CASL. As a general rule, you will be prohibited from sending CEMs to recipients who have not opted in to receiving them. Referral Exemption The ECPA permits an exemption to the rule for referrals. Any person is permitted to send one commercial electronic message without consent, based on a referral by another individual with whom the sender has an existing business relationship. The Foreign Account Tax Compliance Act (FATCA) The government of the United States (US) has long been concerned that certain US taxpayers were evading the payment of taxes by investing offshore. The US Foreign Account Tax Compliance Act (FATCA) targets those taxpayers. © 2021 IFSE Institute 23 Unit 1: Regulatory Environment FATCA requires foreign financial institutions, including firms in the Canadian financial sector, to report about: financial accounts held by US taxpayers foreign entities in which US taxpayers hold a substantial ownership interest If a Canadian financial institution does not comply with FATCA, it faces a 30% withholding tax on certain USsource payments made to it. This is extremely punitive and constitutes a powerful incentive to comply. In order to facilitate compliance with FATCA, the Canadian and US governments have entered into an InterGovernmental Agreement (IGA) which has been incorporated into Part XVIII of the Income Tax Act of Canada (ITA). Under Part XVIII of the ITA, Canadian financial institutions, including mutual fund dealers, must: identify accounts held by clients who are a US person for US tax purposes report to the Canada Revenue Agency (CRA) specified information about the accounts identified as being held by US persons Identifying US Persons In general, a person is a US person for US tax purposes if that person is a US resident or a US citizen. However, a person that has economic and social ties that are closer to Canada than the US would not generally be considered to be a US resident. Existing Clients In order to identify existing clients under FACTA, Canadian financial institutions must review information already in its possession for indications that the client may be a US person, for example a US address. If there is such an indication, the Canadian financial institution must ask the client to certify whether they are a US person. The client may be asked to provide supporting documentation if they claim not to be a US person. New Clients In order to identify new clients under FACTA, Canadian financial institutions must ask clients to certify whether they are a US person at the time that the account is opened. The firm must then confirm the reasonableness of the client’s certification based on the other information provided by the client when opening the account. Alternatively, the firm may follow a process similar to that described above for existing clients, based on the information provided by the client when the account is opened. 24 © 2021 IFSE Institute Canadian Investment Funds Course Failure to Cooperate If a Canadian financial institution has information in its records that shows that a client may be a US person, and the client refuses to cooperate in clarifying his or her status, the firm must report the account as a US account to the Canada Revenue Agency (CRA). CRA will report information about the account to the US Internal Revenue Service (IRS). Accounts Identified as US Persons For accounts identified as being held by US persons, Canadian financial institutions (including mutual fund dealers) must report the following information to CRA: information about the account holder (e.g. name, address, the individual’s US taxpayer identification number) certain financial information pertaining to the account CRA, in turn, will automatically report the information to the IRS. By complying with Part XVIII of the ITA, Canadian financial institutions avoid being exposed to the punitive 30% withholding tax under FATCA. As a Dealing Representative, you should familiarize yourself with your dealer’s policies and procedures regarding FATCA. You may have responsibilities for identifying clients who are US persons, particularly at the time of account opening. © 2021 IFSE Institute 25 Unit 1: Regulatory Environment Summary Congratulations, you have reached the end of Unit 1: Regulatory Environment. In this unit you covered: Lesson 1: Regulatory Bodies Lesson 2: Legislation and Regulations Now that you have completed these lessons, you are ready to assess your knowledge with a 10-question quiz. To start the quiz, return to the IFSE Landing Page and click on the Unit 1 Quiz button. 26 © 2021 IFSE Institute