The correct answer is B . CIRO places primary responsibility for compliance with KYC requirements on the Registered Representative, Portfolio Manager or Associate Portfolio Manager assigned to the client account . IDPC Rule 3209(2) expressly provides that this responsibility “must not be delegated to any other person.” Therefore, an RR cannot transfer their regulatory KYC responsibility to an Investment Representative and treat the IR's periodic updates as satisfying the RR's obligation.

An IR may perform permitted administrative or client-service functions within the scope of their approval, but the assigned RR remains accountable for ensuring that KYC information is appropriately collected, understood, maintained and used in fulfilling suitability responsibilities. This distinction is critical because an RR provides recommendations and must understand the client's circumstances before determining that an investment action is suitable and puts the client's interest first.

The 12-month frequency is not the problem. CIRO generally requires suitability-related KYC information to be reviewed at least every 36 months , while managed and discretionary accounts require review at least every 12 months , and significant changes must be addressed within a reasonable time. Thus D is incorrect. A is also incorrect because IRs may communicate with clients, while C reverses the RR's role.

Study Guide Reference: CIRE Element 3.1 — RR responsibility for collecting KYC; Retail Securities Exam Element 1.7 — primary responsibility, prohibition on KYC delegation and keeping KYC current; IDPC Rule 3209.

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