IIAC Blog

June 24, 2019

Suggested Practices for Engaging With Older and Vulnerable Clients

The Canadian Securities Administrators (CSA) published a Staff Notice offering suggested practices on matters that registrants may consider when working with older or vulnerable clients, including:

-Red flags of diminished mental capacity

-Red flags of financial exploitation

-Know your client and suitability obligations

-Complaint handling

-Supervisory procedures

-Powers of attorney and limited trading authorizations

-Training employees on identifying potential financial exploitation and diminished mental capacity

-Identifying trusted contact persons

-Establishing written policies and procedures for reporting and escalating issues

-Communicating with older or vulnerable clients

The CSA recognizes that older clients are not a homogenous group and that not all older clients are vulnerable or unable to protect their own interests. Vulnerability can affect a client of any age, take many forms, and can be temporary, sporadic or permanent in nature. The CSA encourages registrants to be mindful of, and adapt their practices to reflect, the diverse circumstances and needs of their clients.

The IIAC released similar guidance in 2014, Canada’s Investment Industry: Protecting Senior Investors – Compliance, Supervisory and Other Practices When Serving Senior Investors. You can access it here.