With COVID restrictions lifted across Canada, HCI is returning to normal procedures and ending the temporary measures that were put in place to accommodate conducting business remotely. We thank you for your resilience and efforts to support your clients’ needs and expand your businesses while navigating the various COVID challenges.
We are pleased to have provided an e-signature solution during this time that is being widely used by advisors which is acceptable for HCI transactions and requests. Please note that an original client signature may still be required by some fund companies to designate and/or make changes to the beneficiary on an account, etc.
COMPLETING A NEW KYC OR KYC UPDATE FOR EXISTING CLIENTS ON A NON-FACE-TO-FACE BASIS?
Complete the KYC or KYC Update by phone or during a virtual meeting with the client and forward to the client for e-signature.
COMPLETING A KYC AND IDENTIFYING NEW CLIENTS ON A NON-FACE-TO-FACE BASIS?
Conduct a virtual meeting with the prospective client. You may choose to record your meeting if you have the technology and client permission to record.
Complete the KYC process with the client and send the completed KYC to the client for e-signature.
As per FINTRAC requirements you cannot rely on viewing government issued ID, such as a Driver’s License or Health Card, when meeting a new client virtually or by phone, and you must confirm the identity of the individual(s) by using the DUAL PROCESS METHOD as detailed below.
Complete and submit the Dual Process Method Form found in the forms area on HUBLink. This form, along with the two source documents relied upon for this method, must be included with the KYC when it is uploaded to the KYC History in RepVision.
DUAL PROCESS METHOD
You can verify the identity of an individual using the Dual Process Method. This involves referring to information from two different reliable sources. To verify an individual's identity by using the dual-process method, you must refer to a combination of information from any two of the following Categories: A +B or A+C or B+C.
Category A - Examples of information issued by a Canadian government body that includes the individual's name and address; CPP statement, property tax, CRA Notice, utility bill (electricity, water, telecommunications, etc.), T4 statement, Record of Employment, Registered a/c statement (RRSP, RRIF, etc.), Provincially issued vehicle registration.
Category B - Examples of information issued by a Canadian government body that includes the individual's name and date of birth; CPP statement of contributions, original birth certificate, Marriage certificate, Divorce documentation, Permanent resident card, Citizenship certificate, Employer benefits statement, Canadian Passport, Insurance documents (auto, home, life).
Category C - Examples of information from a reliable source to verify name and confirm financial account: Credit card or other loan account with a financial entity. i.e. Bank statement, Credit card statement, Loan account statement.
Please reach out to your Regional Compliance Officer if you have any questions regarding HCI procedures.
Cheryl Hamilton
Vice President Risk Management and Chief Compliance Officer
