Get ready for the 2020 Risk Assessment Questionnaire

We are writing to provide you with advance notice that on April 15, 2020 you will receive a risk assessment questionnaire (2020 RAQ) from staff of the Ontario Securities Commission (OSC). You must complete and submit the RAQ online by May 27, 2020.

We strongly encourage you to start planning and allocating resources to this initiative. Questions in the 2020 RAQ will be substantially similar to those in the RAQ that was issued in 2018 (2018 RAQ). We have made some important changes to the 2020 RAQ that you need to review before starting your preparations. Please refer to “Summary of key changes to the 2020 RAQ” below.

A copy of the 2018 RAQ can be found here.

The 2020 RAQ will be asking for information for the period(s) ending December 31, 2019.

If you do not receive an email on April 15, 2020, please contact us as soon as possible at [email protected]

To assist you in completing the RAQ, we will be providing a list of frequently asked questions (FAQs), a User Guide, a Help Page for each section of the RAQ, and the contact information of dedicated staff members to whom you can direct your questions. We will also be offering both a webinar and an in-person Registrant Outreach session on this topic, which will be scheduled in April 2020. To register, please visit the outreach webpage on the OSC website.


Summary of key changes to the 2020 RAQ

  1. Pre-populating certain questions with responses from the 2018 RAQ

As part of OSC’s burden reduction initiatives, we have evaluated our ability to pre-populate certain fields in the RAQ. If your firm has completed the 2018 RAQ, certain questions in your 2020 RAQ will be pre-populated. Those questions that have few or no year over year changes will be pre-populated.

For example, we have pre-populated the non-financial information in the question that asks you to provide details regarding your referral arrangements (question G10 in the General Section of the 2018 RAQ). You are not required to re-enter details of each arrangement that you had previously entered into the 2018 RAQ.

We will not pre-populate fields that request financial information (e.g. referral fees paid, revenues, assets under management, capital raised, etc.) or numeric data (e.g. number of clients, number of complaints, performance returns, etc.) since that information changes year over year.

You must review the pre-populated responses and where necessary make changes when the answers no longer accurately describe the firm’s current situation or practices.

  1. Authentication to enhance data security

To further enhance security of your firm’s pre-populated information, we have put in place a different process to the 2020 RAQ.

  • The RAQ will be sent to only one person at the firm. An email will be sent to your chief compliance officer (CCO) on April 15, 2020.
  • The email will contain a link for your CCO to create an account that is unique to your firm in our system. Once the account is created, the CCO will then be granted access to your firm’s 2020 RAQ through this account.
  1. Prospectus-Exempt Fund Form separated from the RAQ

The Prospectus-Exempt Fund Form (Fund Form) has been removed from the 2020 RAQ. Going forward, the Fund Form will be sent separately from the RAQ.

4) UDP certification

Your ultimate designated person (UDP) is required to certify in each section of the RAQ that they have reviewed all of the responses, including the pre-populated information. Please make sure that sufficient time is scheduled for your UDP to complete the certification.

5) Deleted questions

To further streamline the RAQ and to reduce burden, we have deleted a number of questions from the RAQ.

The 2020 RAQ will not have the following questions:

General section in the 2018 RAQ: G3, G6, G7, G13, G18, G20

PM section in the 2018 RAQ: P9 – part B

IFM section in the 2018 RAQ: F4 – part C

EMD section in the 2018 RAQ: E12 – part C and part D

6) Portfolio Manager and Restricted Portfolio Manager Section

Question P1 has been amended and requires you to breakdown the firm’s assets under management (AUM) as at Dec. 31, 2018 and Dec. 31, 2019 using the following categories:

Row A.     Individuals

Row B.     Institutions (refer to the revised definition of “institutional clients” which includes only third-party investment funds where your firm is the PM to the funds)

Row C.     Investment funds where your firm is both the PM and IFM

To avoid double counting, exclude from row C the AUM of investment funds that your firm manages and your individual or institutional clients are invested in. For example, if you have AUM of $1,000,000 from your individual managed account clients and that amount is invested in your proprietary investment funds, enter $1,000,000 in row A under “individuals” and enter $0 in row C under “investment funds where your firm is both the PM and IFM.”  Refer to the Help Page in the PM section of the 2020 RAQ for additional examples on how to complete this question.

7) Exempt Market Dealers and Restricted Dealers Section

Question E8 has been amended. We have revised the list of business/industry of the investment products to align with the industry sectors under the Global Industry Classification Standard (GICS), which include financials, energy, materials, industrials, communication services, information technology, utilities, consumer discretionary, consumer staples, real estates and health care.

As a result of this change, questions E10 and E11 in this section have also been amended to reflect the same change as E8 in the list of business/industry categorization.