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Letter Summary:
The Consultation Document seeks feedback on CE requirements for Approved Persons of MFDA member firms. The proposal would establish a minimum number of credits for dealing representatives, as well as a minimum number of credits for Chief Compliance Officers, Ultimate Designated Persons and branch managers that would need to be achieved in a 24-month cycle. The proposed CE program would include three components: business conduct; professional development; and MFDA compliance.
Overview of the Council’s Comments:
The CAC is of the view that continuing education requirements for membership in the MFDA would be a positive requirement and further welcome in a world where mutual funds sold are increasingly complex. It notes however, that there could be some harmonization done with other self regulatory organizations, for example IIROC.