This communication provides guidance and reminders regarding HUB Capital Inc.’s (“HCI”) recent Sales Practices Audit with CIRO and updates to the KYC and KYC Update Forms.
Over the past four years, significant regulatory changes have been introduced through Client Focused Reforms. We appreciate your efforts in implementing these changes to enhance policies, procedures, and recordkeeping within your practice.
The recent CIRO Audit identified a few areas requiring updates to the KYC, KYC Update, Trusted Contact Person, and Conflict of Interest Disclosure forms. The updated forms are now available on HUBLink. Please ensure all previous versions are destroyed to maintain compliance.
Below is a summary of the changes to these forms and additional guidance on client disclosure procedures.
1. KYC Form and KYC Update Form – Risk Capacity, Risk Attitude, and Risk Profile
Assessing a client’s Risk Capacity and Risk Attitude is crucial to determining their overall Risk Profile, a regulatory requirement advisors must fulfill before making any client recommendations. This assessment is mandatory for both initial and ongoing KYC requirements and updates.
The HCI Investor Profile Questionnaire (IPQ) was initially provided as a tool to help determine KYC information and risk profiles. However, much of the information overlapped with the KYC form. The newly updated KYC and KYC Update forms now incorporate the client’s Risk Profile (encompassing Risk Capacity and Risk Attitude) to streamline the process and better guide advisors in determining Risk Tolerance at the plan level. These enhancements aim to provide greater clarity for both advisors and clients in understanding how the Risk Profile is established, considering both capacity and attitude toward risk. Use of the IPQ remains optional, as outlined below.
KYC and KYC Update – Risk Profile Questions
Questions regarding a client’s Risk Capacity and Risk Attitude, which together determine the Risk Profile, are now included on page 2 of the updated KYC and KYC Update forms:

Risk Capacity
Risk Capacity represents a client’s financial ability to withstand a loss of capital. Key factors such as the client’s age, financial situation (including income and savings), and investment time horizon must all be considered in this assessment.
Risk Capacity is evaluated at the client level and categorized as Low, Medium-Low, Medium, Medium-High, or High. Advisors must indicate the client’s Risk Capacity by selecting the appropriate checkbox on the KYC form.
Risk Attitude
Risk Attitude reflects a client’s comfort level with risk, particularly their tolerance for return volatility. Unlike Risk Capacity, Risk Attitude is assessed at the plan level and may vary across different plans.
Advisors are required to discuss the client’s Risk Attitude for each plan. This assessment is a critical factor in determining the client’s Risk Profile (Risk Tolerance) for each plan.
Risk Profile
The client’s Risk Profile is determined by the lower of their Risk Capacity and Risk Attitude, rather than an average of the two. Once established for a plan, the Risk Profile should be recorded under the “Risk Profile (Risk Tolerance)” section of the KYC form.

Important Reminder:
The HCI TCP Form is exclusively for HUB Capital business and is the only approved form for designating a Trusted Contact Person (TCP). It is not intended for use in any other client-related activities outside of HCI, such as insurance or financial planning.
3. Updates to Conflict of Interest (COI) Disclosure Form
Minor revisions have been made to the Conflict of Interest (COI) Disclosure Form. The updated versions are available on HUBLink and should be downloaded and used to reflect your outside activities, businesses, and trade names.
Please ensure these updated forms are used for all future client interactions.
To notify clients of the COI Disclosure changes, HCI will be adding a disclaimer to the Q4 Client Statements. As a result, advisors are not required to distribute the revised form to existing clients at this time.
4. Reporting of Client Complaints to HCI
As a reminder, according to section 2.13 of HCI’s Policy and Procedures Manual, client complaints, including service issues, must be reported to HCI Compliance within 2 business days. This ensures timely review and determines whether regulatory reporting or client acknowledgment is required.
5. 2025 Best Practices Guide
Please refer to the HCI Best Practices Guide for guidance. The 2025 edition will be available in early January. The aim of this guide is to support your compliance with regulatory requirements while allowing you to focus on growing and safeguarding your business throughout the year.
If you have any questions or would like additional training or support, please don’t hesitate to contact your Regional Compliance Officer, who will be happy to assist you.
Best regards,
Cheryl Hamilton
Vice President Risk Management and Chief Compliance Officer