Option C reflects CIRO’s expressly stated KYC documentation practices. Dealer Members must take reasonable steps to have clients confirm the accuracy of the information collected during the KYC process. CIRO guidance further identifies recording the date on which the information was collected as a best practice and requires the dealer to maintain evidence that the client confirmed its accuracy. Confirmation may be evidenced through a signature, an electronic acknowledgement or detailed notes recording the client’s instructions and confirmation.

Option A is inadequate because confirmation is not limited to substantial portfolio changes. KYC information must be confirmed after collection and kept current when significant changes occur. Option B may be relevant for limited identification or anti-fraud checks, but a Dealer Member and Registered Representative cannot substitute third-party data for meaningful interaction with the client concerning financial circumstances, objectives, risk profile, investment knowledge and time horizon. Option D does not satisfy the regulatory requirement because predictive technology cannot replace direct client confirmation or the dealer’s responsibility for accurate records.

The Retail Securities syllabus requires accurate documentation of client discussions and client confirmation of the information. It also includes maintaining KYC records as a specific examination outcome. The prescribed approach is therefore to date the information, obtain confirmation, preserve evidence and update the record when necessary.

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