Email Blast – Get Ready for the 2022 Risk Assessment Questionnaire

We are writing to provide you with advance notice that on May 4, 2022, you will receive a risk assessment questionnaire (2022 RAQ) from staff of the Ontario Securities Commission (OSC). You must complete and submit the RAQ online by June 15, 2022.

We strongly encourage you to start planning and allocating resources to this initiative. Questions in the 2022 RAQ will be substantially similar to those in the 2020 risk assessment questionnaire (2020 RAQ). We have included below some important information that you need to review before starting your preparations. Please refer to “Summary of key information to the 2022 RAQ”.

We ask that you please review the email address of the firm’s Chief Compliance Officer (CCO) and Ultimate Designated Person (UDP) on the National Registration Database to ensure that they are up-to-date and accurate as these email addresses will be used to create separate accounts to access the 2022 RAQ. Please ensure that this is done by February 28, 2022.

Firms registered as Investment Fund Managers in Ontario received the OSC’s Investment Fund Survey (the Survey), which has a deadline to complete of April 29, 2022. We acknowledge and appreciate the resources and time that must be devoted to completing both the Survey and the 2022 RAQ. Providing you with this advance notice should help you plan and allocate compliance resources to both the Survey and the 2022 RAQ, which will be issued on May 4, 2022.

A copy of the 2020 RAQ can be found here.

The 2022 RAQ will be asking for information for the period ended December 31, 2021.

If you do not receive an email on May 4, 2022, 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 a webinar Registrant Outreach session on this topic, which will be scheduled in May 2022. To register, please visit the outreach webpage on the OSC website.

Summary of key information to the 2022 RAQ

1. Pre-populating certain questions with responses from the 2020 RAQ

We will continue to pre-populate certain fields in the 2022 RAQ. If your firm completed the 2020 RAQ, certain questions in your 2022 RAQ will be pre-populated. Those question that we anticipate having 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 G7 in the General Section of the 2020 RAQ). You are not required to re-enter details of each arrangement that you had previously entered into the 2020 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.

2. Authentication to enhance data security

The 2022 RAQ will continue to be accessible only through the creation of a unique account. If the firm created an account to access its 2020 RAQ, there is no need to find or remember your old account password as new accounts will need to be created.

An email will be sent to your CCO and UDP on May 4, 2022 with information necessary to access and complete the 2022 RAQ.
The email will contain a link that will allow both the CCO and UDP to create separate accounts that are unique to your firm in our system. Once an account is created, you will be able to access your firm’s 2022 RAQ through this account.
The accounts for the CCO and UDP will be associated with the email addresses for your firm on the National Registration Database, so please ensure that these email addresses are up-to-date and accurate.

3. UDP certification

Your 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. As the UDP has their own account in our system, they will be able to complete this certification process through their account. If the UDP and CCO are the same person, then their firm will only have one account and that account can be used to complete the UDP certification.

4. Changes made to the questions in the risk assessment questionnaire

Question F4 in the Investment Fund Manager section has been amended to also capture information on the sub-custodian(s) that your custodian(s) may utilizes to hold assets of your investment funds.
Question P2 in the Portfolio Manager (PM) section, where we ask the firm to provide a breakdown of the types of securities held by your clients, we are now permitting negative percentages to allow firms to report short positions. In addition, we have also included as its own category the asset class of Crypto.
Question P3 in the PM section, where we ask firms to report the investment strategies they follow, we have added in the additional option of Quantitative methods.