With advances in technology and the desire for advisors to be more efficient in obtaining client documents electronically, we are pleased to advise that effective immediately, HCI advisors may choose to have clients sign HCI and Fund Company documents (as permitted by the fund company) using DocuSign eSignature as per the following polies and procedures:
Electronic Signatures
HUB Capital Inc. (“HCI”) and its APs are permitted to accept signatures from clients by electronic means (“e-signature”) providing there are procedures in place to ensure client consent, the integrity of the document, audit trail and safeguarding of confidential client information.
HCI has approved DocuSign eSignature (“DocuSign”) and the following policies and procedures to ensure the above requirements are met when obtaining e-signatures on client documents:
- All communications providing clients with passwords to access documents distributed for e-signature by DocuSign are to be provided to the client verbally, securely by email using @hubcapital.ca email addresses or by SMS text messaging;
- Careful consideration is required when creating unique passwords for each client to ensure the protection of confidential client information and strong password strength;
- Passwords must not include identifiable information i.e. Client Name, Client ID, SIN, etc.;
- A new password is required for every document or document package that requires a client to sign electronically; HUB Capital Inc.
- Clients will not be required to sign documents electronically; however, in choosing the esignature option they will be consenting to signing the document(s) electronically and to receiving the disclosure information electronically as part of the DocuSign document delivery process;
- Documents must be completed in full prior to distribution to the client(s) for e-signature with the primary client designated as the first signatory followed any co-client signatory or additional signatories on the account. The AP is the last signatory which is important in providing the opportunity for the AP to review and sign the document prior to completing the e-signature process and subsequent processing of the document;
- Clients must be provided with a fully executed copy of any documents signed electronically;
- Documentation signed using e-signatures must include the Completion Certificate to be considered in good order (IGO);
- Documentation signed using e-signatures, including the Completion Certificate, must be uploaded to the client record.
Electronic signatures are permitted on all HCI account operation and transaction forms with the exception of the initial KYC for a new client. Fund Company forms may also be completed using electronic signature as permitted by each Fund Company.
Thank you,
Cheryl Hamilton
Vice President Risk Management and Chief Compliance Officer
