Client Focused Reforms (CFRs) – Phase II: What You Need to Know for Implementation

Speakers: Jennie Baek and Jason Chertin


November 17, 2021: Agenda

Event Time: 1:00 pm - 2:00 pm (ET)

The December 31, 2021 deadline for registered firms and their representatives to comply with the second phase of the Client Focused Reforms (CFRs) is fast approaching. Phase II of the CFRs implements all other changes with respect to the CFR amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations, aside from the conflicts of interest requirements, which took effect earlier this year. These amendments may require updates to a wide range of processes, procedures, and obligations, including with respect to:

  • misleading communications, including titles
  • know your product (KYP), know your client (KYC), and suitability obligations
  • relationship disclosure information (RDI) and on-boarding processes and procedures
  • training and recordkeeping obligations
  • internal controls and systems

Registrants who have not yet started assessing the impact of these new requirements should start the process now and attend this webinar to gather additional information. Join McMillan for a discussion on practical questions and issues related to the new requirements and how they may impact your organization. Topics include:

  • Overview of the Phase II requirements
  • Key issues and practical tips to assist with compliance
  • Other changes to consider implementing concurrent with the CFR amendments
  • FAQs


  • Jennie Baek, Partner, Investment Funds and Asset Management
  • Jason Chertin, Partner, Investment Funds and Asset Management