2012 regulatory year in review - canada & u.s. · 2019. 5. 6. · presentation outline...

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Compliance Officers’ Network December 4th, 2012

2012 Regulatory Year in Review - Canada & U.S.

Presentation Outline

Regulations Impacting PMs

A. Canada Securities Regulation Federal Regulation

B. PMAC Compliance Tools

C. United States FATCA CRTC Exemptions SEC Large Trader Reporting Rules Foreign Private Advisor

Q & A

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Regs impacting PMs - Canada

1. Securities Regulation Consultation Papers

Accredited Investor Exemption and Minimum Amount

Potential Regulation of Proxy Advisory Firms

Statutory Fiduciary Duty

Dispute Resolution - CSA Proposal to Mandate OBSI

New IFM Registration Instruments

CRM II

KYC & Suitability

NI 23-103 Electronic Trading

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Dispute Resolution Service

NI 31-103 – Section 13.16

January 2012

PMAC ADRIC Dispute Resolution Service

November 2012

CSA Proposal to Mandate OBSI

All registered dealers and advisers, outside of Québec, required to use

Ombudsman for Banking Services and Investments (OBSI) as the common

dispute resolution service for securities industry

6 year limitation period on claims

$350,000 max on claim amount

Under current OBSI funding model, all participating firms pay a levy based on their size or volume of business

CSA has been working with OBSI to develop a fee model

Deadline to comment: February 15, 2013

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New IFM Registration Instruments

A bifurcated regulatory framework effective September 28, 2012

1. Multilateral Instrument 32-102 Registration Exemptions for Non-Resident

Investment Fund Managers (MI 32-102)

Governs the activities of non-resident IFMs in Ontario, Québec and

Newfoundland and Labrador

2. Multilateral Policy 31-202 Registration Requirement for Investment Fund

Managers (MP 31-202)

Governs the activities of non-resident IFMs in all other Jurisdictions

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MI 32-102 Triggering registration in the case of non-resident investment fund managers will

depend on whether the manager acts as an investment fund manager and whether that manager is managing one or more investment funds that have distributed securities to residents of the local jurisdiction

If these two conditions are met, registration requirement applies, subject to available exemptions

Two registration exemptions available:

• Where there are no security holders of any of the investment funds managed by the investment fund manager, or active solicitation, after September 27, 2012, by either the investment fund manager or any of the investment funds it manages, of residents in the local jurisdiction

• An exemption, available only to an international investment fund manager without a place of business in Canada, in circumstances where all of the Canadian distribution of the securities of the investment funds managed by the investment fund manager was restricted to permitted clients

Deadline to register: December 31, 2012

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MP 31-202

MP 31-202 adopts a principles based approach

Emphasis on actually acting as an IFM within a Policy Jurisdiction rather than having security holders resident in the Policy Jurisdiction

Does not provide any "bright line" exemptions from registration

Identifies functions or activities that are indicative of a person or company that directs or manages the business, operations or affairs of an investment fund and thereby acts as an IFM for purposes of IFM registration requirements of the Policy Jurisdictions

An IFM is required to register in a Policy Jurisdiction if it directs or manages the business, operations or affairs of an investment fund from a physical place of business in the Policy Jurisdiction or if its head office is located in the Policy Jurisdiction.

In determining whether registration is required, a non-resident IFM must consider what functions or activities, if any, that it is directing from within a Policy Jurisdiction, and, for such purpose, no single function or activity is determinative

Deadline to register: December 31, 2012

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CRM II Client Relationship Model Phase 2 (CRM II) proposals published June 2011 and

publication for second comment June 14, 2012

Applies to all dealers and advisors (including SRO members)

Cost Disclosure

Goal: Give investors enhanced general cost (charges) information (at account opening, when transacting, and annual summary of all amounts charged by registrant to client and dollar amount of compensation from third parties)

Key Issue: Using book cost instead of original cost

Performance Reporting

Goal: To enable investors to evaluate how well their investments are doing so they can make informed decisions about meeting their goals and objectives assess the value added by their registrant

Key Issue: For calculating percentage returns, mandate dollar weighted method over time weighted

Expected Timeline: June 2013 (with up to 3 year transition)

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Focus on KYC & Suitability

Regulators continue to identify significant deficiencies in compliance by some

registrants with their KYC and suitability obligations and unsuitable investments are a

common subject of investor complaints

Trapeze Asset Management Inc. – Settlement Agreement

Suitability sweep and new OSC initiative to contact investors

June 2012 - targeted review (sweep) of over 85 EMDs and PMs

OSC contacted approx. 200 investors

o all agreed to speak to OSC

o some asked to call them back to ensure they were speaking to OSC

o purpose of calls to confirm IPS content)

o OSC intends to continue with the practice in all reviews

Expected Timeline: OSC Staff Notice to be released in 2013

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NI 23-103 Electronic Trading

• Adopted in June 2012 and intended to address the risks of electronic trading

• Relevant for PMs and EMDs who used direct electronic access (DEA) to directly send trade

orders to marketplaces

• Rule permits PMs to use DEA when it is provided by a participant dealer for trading in their own accounts or the accounts of their clients

• Participant dealers that provide DEA to PMs are subject to additional requirements including

o standards to be applied before granting DEA to a PM,

o specific elements to be included in a written agreement with the PM,

o training the PM, and

o assigning a unique identifier to each PM for each of their orders.

In effect on: March 1, 2013

• October 2012 – Proposed amendments to NI 23-103 intended to address need for

appropriate controls to manage risks with providing DEA

o Limits registrants that may provide DEA to fully registered dealers, and limit those that

may use DEA to PMs and restricted portfolio managers (thereby EMDs)

Deadline to comment : January 23, 2013

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2. Federal Regulation

Prohibited Investment Rules

Anti-Money Laundering and Anti-Terrorist Financing

• Amendments to Regulations

• FINTRAC Audits

Canada's Anti-Spam Legislation (CASL)

• CRTC Anti-Spam Regulations

• Guidelines

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Prohibited Investment Rules

• See Part XI.01 of the Income Tax Act (Canada) - applies to investments made by RRSPs,

RRIFs and TFSAs

• Investment considered prohibited investment if: 1) Planholder has a “significant interest “ in a fund, issuer, trust , partnership (planholder alone or

together with non-arms length persons owns, directly or indirectly more than 10%) 2) Planholder does not deal at arm’s length with the fund 3) Planholder has a “significant interest” in an entity (i.e. fund manager) that does not deal at arm’s

length with the fund, issuer, etc.

• Severe penalties: 50% penalty tax if holding / acquire an investment that is prohibited and 100% penalty

tax if “advantage”

• Department of finance recommending changes to rules: o Narrow the definition of “prohibited investment” to repeal 3) above (ex, an investment in a fund

will not be prohibited investment for registered plan simply because planholder holds, for example, 10% or more of a class or series of shares of the fund manager)

o However, if planholder holds controlling interest in fund manager, planholder could be considered not to deal at arm’s length with funds managed by that fund manager (prohibited investment)

Expected Timeline: Late 2012/Early 2013 (amendments to be published for comment)

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Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF)

• Various amendments/consultations over last few years to strengthen AML and ATF regime

• October 13, 2012 - Department of Finance published draft amendments to the Proceeds of

Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) to improve

Canada's compliance with the Financial Action Task Force's Recommendation 5 (now

reformulated as Recommendation 10) • Definition of "business relationship” • Ongoing monitoring to detect reportable transactions • Beneficial ownership • High risk clients

• PMAC 2012 Events

o How to Survive a FINTRAC Audit

o AML Compliance – Training your Employees

o FINTRAC Speakers at 2012 Compliance Forum

• FINTRAC Audits

o FINTRAC compliance assessment report requests

o Are continuing into 2013

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Canada's Anti-Spam Legislation (CASL) • Received royal assent on December 15, 2010

• CASL generally prohibits things such as: o sending of commercial electronic messages (CEMs) without the recipient's consent (permission),

including messages to email addresses and social networking accounts, and text messages sent to cell phone

o alteration of transmission data in electronic message which results in message being delivered to different destination without express consent

Regulations • Original draft regulations were published summer of 2011 by CRTC and Industry Canada

• Canadian business community raised serious objections to strict requirements

• CRTC enacted revised regulations, which were finalized on March 28, 2012 (eased up on some of the more onerous requirements)

• Revised draft regulations from Industry Canada are expected shortly (also expected to ease up on certain requirements and may contain new exceptions)

• The CRTC has published two information bulletins to help businesses better understand CASL

Start reviewing existing activities now to prepare for compliance and coming into force of CASL (Visit www.fightspam.gc.ca for updates)

Expected Timeline: CASL is expected to be in force in 2013 (specific date to be set soon)

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http://www.fightspam.gc.ca/

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PMAC Compliance Tools

Updated Templates

Investment Policy Statement (Feb 2012)

Conflict of Interest Template (Feb 2012)

Principles of Corporate Governance (Feb 2012)

Personal Trading Guidelines (June 2012 )

New Templates/Guidelines

Guideline on Preparing a BCP

Guideline on Preparing an Annual CCO Report to the Board

(Coming Soon!)

KYC Best Practices (Coming Soon!)

Regs impacting PMs – U.S.

1. FATCA

2. CRTC Exemptions

3. SEC Large Trader Reporting Rules

4. Foreign Private Advisor

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Q & A

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FATCA Overview for PMAC members Lisa Stanley, Tax Senior Manager Deloitte & Touche LLP December 4, 2012

August 2012

© 2012 Deloitte Global Services Limited © 2012 Deloitte Global Services Limited

FATCA overview FATCA’s central purposes is simple: to identify U.S. taxpayers who hold financial assets in non-U.S. financial institutions and other offshore accounts, so that they cannot avoid their U.S. tax obligations

What is FATCA?

• Enacted in 2010 as a part of the Hiring Incentives to Restore Employment (HIRE) Act, the goal of FATCA is to improve tax compliance involving U.S. persons with

foreign financial assets and offshore accounts

• U.S. withholding agents (USWAs) and participating foreign financial institutions (FFIs) are required to document account holders and withhold on non-compliant accounts

• FFIs are required to enter agreements with U.S. Treasury to identify and report U.S. accounts annually

• Non-financial foreign entities (NFFEs) are required to

report substantial U.S. owners or certify no U.S. ownership

What is compliance?

• FFIs can be categorized as participating, non-participating, or deemed compliant

• Non-compliant FFIs and NFFEs are subject to 30% withholding on U.S. source income, U.S. gross proceeds and certain foreign source payments resourced as

withholdable under FATCA (foreign passthru payments)

• Non-compliant policy holders subject to withholding on passthru payments

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Entity classification

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Possible

classifications Comment

Participating FFI or Registered FI

Full obligations for identifying, monitoring, withholding and reporting to the IRS

Under IGAs all FFIs within a local country will register with the IRS

Definition under IGA generally includes custodial institutions, depository institutions and investment entities (any entity that conducts one or more of the following activities or operations

for or on behalf of a customer:

• Trading in money market instruments (checks, bills, certificates of deposit, derivatives, etc.,); foreign exchange; exchange, interest rate and index instruments; transferable securities; or commodity futures trading;

• Individual and collective portfolio management; or

• Otherwise investing, administering, or managing funds or money on behalf of other persons.

Deemed-Compliant

FFI Generally does not withhold or report; must certify status

• Must be licensed and regulated under local country laws

• Must perform either information reporting or withholding of tax to the local country on accounts held by residents

• Still must identify and monitor customer base; cannot maintain US resident customers without reporting

1471(f) Exempt Beneficial Owner

Generally includes governmental or international organization, and listed retirement and pension

plans; does not include investment managers

Non-Financial Foreign Entity (NFFE)

Provides certification of NFFE status to financial institutions and investments; certification depends upon type of NFFE (i.e., Active = Exempt from reporting, Passive = Identify whether US or any US controlling persons, FI reports)

Non-Participating FFI Subject to 30% withholding; eventually 30% may be applicable to foreign source payments from other FFIs (no sooner than 2017)


Classify entities in the reporting financial institution’s group

Determine what products covered; classify pre-existing individual and entity “accounts” for FATCA

Classify new “accounts” for FATCA and capture “self certification” data

Withholding not required on recalcitrant accounts but is required on non-participating FFIs resident in non-IGA countries Register with IRS in some

capacity

Entity classification

Pre-existing accounts

classification

New investor requirements

Compliance

Agreements

Withholding

Reporting Achieving FATCA

compliance

Compliance enforced by various measures including penalties

Report information on U.S. accounts to relevant tax authority

FATCA obligations under potential IGAs

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How does the Portfolio Management industry?

• Determine whether FFI or NFFE status and whether any exceptions or deemed compliant status apply

• If an FFI -

• Review investors and documentation currently collected

• Determine any changes to investor documentation under FATCA

• Review relationships and expectations of third party service providers

• If a third party will be performing FATCA reporting, review agreements and capabilities

of reporting agent

• If withholding may apply, confirm ways of reducing non-compliant investors subject to

withholding

• Consider customer relations approach for requesting additional documentation and

reporting

• If an NFFE or any investors are NFFE

• Determine what procedures will be followed to identify whether controlling persons are

citizens or tax residents of the United States

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Disclaimer This publication contains general information only, and none of Deloitte Touche Tohmatsu Limited, any of its member firms or any of the foregoing’s affiliates (collectively the “Deloitte Network”) are, by means of this publication, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your finances or your business. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this publication. About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms.

http://www.deloitte.com/about

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Nothing herein should be construed as legal advice or as a legal opinion for any particular situation. Information is provided for general guidance and should not be substituted for formal legal advice from an experienced securities attorney.

CFTC Regulation Changes and Implications

Scott Brindley

Principal Consultant

ACA Compliance Group

December 4, 2012

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Commodity Pool, Commodity Pool Operator (CPO) and Commodity Trading Advisor (CTA)

• Commodity Pool: comingled investment vehicle that invests in

“commodity interests”

• CPO: The managing entity of the pool

• CTA: Advising entity to the fund or separately managed accounts

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CFTC Part 4 Changes

4.13(a)(4) “sophisticated investor” rescinded

• The widely relied upon 4.13(a)(4) exemption has been rescinded, effective 12/31/12

• Investors are Qualified Purchasers

4.13(a)(3) “de minimis” remains

• Each pool must meet one of the following two tests:

– The aggregate initial margin/premium required to establish a commodity interest position does not exceed 5% of the pool’s portfolio

– The aggregate net notional value of commodity interest positions does not exceed 100% of the liquidation value of the pool’s portfolio

• Investors are Qualified Eligible Participants

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CPO Exemptions – 3.10(c)(3)

• CPO located outside the United States

• Fund and investors located outside the United States

• Fund is trading commodity interests on U.S. exchanges

• Exemption is self-executing

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CPO Exemptions – Rule 30.4(c)

• CPO of a fund located outside the United States and exempt from registration under the Investment Company Act of (1940)

• Trading solely foreign futures or foreign options, and

• No more than 10% of the investors are US participants and the aggregate value of the fund held by US investors does not exceed 10%

• Exemption is self-executing

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CTA Exemptions- Sections 4m(1), 4m(3) of CEA

• 4m(1) – Available to an advisor that:

– During the preceding 12 months has not furnished commodity trading advice to more than 15 persons, and

– Does not hold itself out generally to the public as a CTA

• 4m(3) – Available to an advisor that:

– Is registered with the SEC as a registered investment adviser (RIA)

– Whose business does not consist “primarily of acting” as a CTA

– Does not act as a CTA to any commodity pool that is “engaged primarily” in trading commodity interests

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CFTC Registration and NFA Membership

• Identify CPOs and CTAs across enterprise

– CPO Delegation

• Identify Principals and Associated Persons

• Submit firm and individual applications on NFA’s ORS

• Proficiency requirement (Series 3)

– Alternative exams (Series 32)

• Fingerprinting and background checks

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Alternatives to the Series 3

Series 32 Exam

Individuals may use Series 32 if, within the two years prior to filing the application, they have been licensed to solicit customer business in futures in Canada.

Registration Rule 402 Waiver

• Trading “principally” in securities transactions

• Limit activity to solicitation in a commodity pool that:

– exclusively trades CFTC-regulated swaps

– if not for swaps trading firm would be eligible for exemption under Rule 4.13(a)(3)

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Nothing herein should be construed as legal advice or as a legal opinion for any particular situation. Information is provided for general guidance and should not be substituted for formal legal advice from an experienced securities attorney.

Scott Brindley, Principal Consultant ACA Compliance Group [email protected]

QUESTIONS?

mailto:[email protected]

© 2012 Dechert LLP

PMAC Compliance Meeting

Large Trader Reporting and

Foreign Private Adviser Exemption

Jane A. Kanter

December 4, 2012

Large Trader: Rule 13h-1 and Form 13H

• Purpose. The purpose of Rule 13h-1 under the Securities Exchange Act of 1934 and Form 13H is to (i) identify large market participants and (ii) collect information on their trading activities regarding NMS securities for analysis by the SEC.

• Large Trader: The Rule defines a “Large Trader” as a person, whether or not based in the United States, that directly or indirectly effects transactions on behalf of itself, or accounts over which it exercises investment discretion, in NMS securities in an aggregate amount, equal to or exceeding either (“Large Trader Levels”):

• 2 million shares or shares with a fair market value of $20 million during any calendar day, or

• 20 million shares or shares with a fair market value of $200 million during any calendar month.

• In determining the Large Trader Levels, offsetting or netting is not permitted.

Large Trader Requirements

• Large Trader. In determining who is a Large Trader it is necessary to consider

transactions in NMS securities made by a person as well as those made through a

“controlled person” or subsidiary

• Transaction. Means “all transactions in NMS securities, excluding the purchase or sale of such securities pursuant to exercises or assignments of option

contracts,” except for certain specifically enumerated transactions.

• FAQs. In its Large Trader FAQ, the SEC provides very good guidance as to how

to calculate the value of transactions in options with respect to NMS securities

that must be taken into account in determining whether a person has reached one

of the Large Trader Levels.

Large Trader Requirements

Rule 13h-1 under the 1934 Act requires persons that are Large Traders to:

• electronically file a Form 13H with the SEC disclosing information regarding their organization and its use of broker-dealers;

• after the initial filing of the Form 13H, the SEC will provide the Large Trader with a unique Large Trader Identifier (“LTID”) that the Large Trader must provide to SEC registered broker-dealers through which it or its controlled persons effect transactions; and

• upon request from the SEC, “promptly” provide additional descriptive or clarifying information regarding accounts at broker-dealers through which it effects transactions in NMS securities.

• To facilitate reporting by affiliated firms, an ultimate parent company may file the Form 13H on behalf of all of its controlled persons and subsidiaries. The SEC explicitly encourages a Large Trader holding company to assign three digit suffixes to the LTID when completing the Form 13H to sub-identify persons, divisions, groups, or entities under the Large Trader’s control.

Non-U.S. Persons • Non-U.S. persons may qualify as Large Traders (and become subject to the Large

Trader Rule and the Form 13H reporting requirements) based on their transactions in NMS securities regardless of where the NMS securities are traded.

• Because non-U.S. persons often effect trades through non-U.S. intermediaries, the SEC requires that:

– Each Large Trader must report each of the SEC registered broker-dealers with which it maintains accounts; and

– Each SEC registered broker-dealer must treat non-U.S. intermediaries for which it executes trades in NMS securities as its customer for purposes of the Rule.

• If a non-U.S. intermediary effects NMS transactions that exceed the Large Trader Levels through an SEC registered broker-dealer, then that SEC registered broker-dealer must inform the non-U.S. intermediary that it may be a Large Trader for purposes of the Rule.

• Non-U.S. Large Traders may also report “non-registered” broker-dealers that handle its transactions in NMS securities.

Non-U.S. Persons

• Form 13H requires basic information about the Large Trader and its Securities

Affiliates (each affiliate that exercises or has authority to exercise investment

discretion over NMS securities).

• For each Large Trader and its Securities Affiliates, Form 13H requires eight (8)

separate categories of information

• If the Large Trader or any of its Securities Affiliates is not a U.S. entity, it must

disclose and identify (among other things):

– its primary foreign regulator;

– the jurisdiction of its organization and organizational status, including

information about each executive officer, director, trustee and general

partner

– each SEC registered broker-dealer at which it has an account and the

services provided by each (e.g., prime broker, executing broker, etc.)

Amendments to Form 13H; Voluntary Filers

• A Large Trader must update its Form 13H:

– on an annual basis, within 45 days after the end of the calendar year, and

– by no later than the end of any calendar quarter in which “any of the information

contained in the Form 13H filing becomes inaccurate for any reason.”

• There is no materiality qualification regarding the requirement to file an amendment

to Form 13H, so quarterly reporting is likely.

• A person may choose to voluntarily register as a Large Trader on Form 13H.

– If so, it will be treated as a Large Trader for all purposes under the Rule.

– This approach may be the preferred choice for persons that do not wish to

monitor the Large Trader Levels on an ongoing basis.

– Many persons that thought they were not Large Traders ended up having to

register as a Large Trader

Confidentiality

• The Rule does not require a Large Trader to:

– identify on Form 13H the individual accounts over which it exercises control, including the broker-dealer used for particular accounts or the account number;

– provide its LTID to other advisers for accounts over which there is shared investment discretion.

• Information included in any Form 13H filing, as well as transaction information provided to the SEC from broker-dealers, is intended to be protected and remain confidential.

• Such information will not be available to the public through FOIA requests.

• However, such information can be provided to Congress and shared with U.S. government departments and agencies.

• Non-U.S. persons may request an exemption from reporting as a Large Trader, if the laws of the relevant jurisdiction prohibit such disclosures.

Foreign Private Adviser

• As you may be aware, certain persons and entities are excluded from the

definition of “investment adviser” in Section 202(a)(11) of the Advisers Act.

• Unlike those excluded from the definition of investment adviser, certain

persons and entities are exempt from registration as an investment adviser

but subject to the Advisers Act and any rules or regulations that apply to

unregistered as well as registered advisers.

• One category of such exempt adviser is so-called “foreign private advisers”

• This exempt from the definition of investment adviser was adopted as part of

the Dodd Frank Wall Street Reform and Consumer Protection Act (“Dodd Frank Act”) on July 21, 2010.

• Rule 202(a)(30)-1, which defines certain terms with respect to the Foreign

Private Adviser Exemption, was adopted on June 22, 2011.

Foreign Private Adviser Exemption

Foreign Private Adviser who:

does not hold itself out as an investment adviser in the U.S nor serves as an

adviser for registered investment companies or registered BDCs.;

has no place of business in the U.S.;

has fewer than 15 clients and investors in the U.S. in private funds advised

by the adviser; and

has aggregate regulatory assets under management (“RAUM”) of less than

$25 million attributable to (i) U.S. clients (including U.S. domiciled private

funds) and (ii) U.S. investors in offshore private funds

Advisers registered with the CFTC as commodity trading advisors (“CTAs”) and

that advise private funds and accounts that invest primarily in commodities.

In terms of a “place of business” in the U.S., this factor is subject to some

interpretation.

Key Defined Terms

• “Investor” means any person who would be included in determining the number of beneficial owners of the securities of a private fund under Section 3(c)(1) of

the 1940 Act or the “qualified purchasers” of a private fund under Section 3(c)(7)

of the 1940 Act and any beneficial owner of outstanding short-term paper issued

by a private fund.

• “In the United States” is defined by reference to Regulation S under the Securities

Act of 1933, except that any discretionary account that is held for the benefit of a

U.S. person by a non-U.S. affiliate of the adviser is deemed to be “in the United States.”

• The SEC’s view is that a separately managed account opened by a person while

not “in the United States” does not become an account that is “in the United States” as a result of the account owner’s subsequent relocation to the United States, even if that person then contributes additional assets to the account. By

contrast, an investor in a fund who relocates to the United States and reinvests in

a fund would become an “investor” with respect to any follow-on investment.

Definitive advice

Practical guidance

Powerful advocacy

Dechert LLP

dechert.com

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2012 regulatory year in review - canada & u.s. · 2019. 5. 6. · presentation outline...

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