Keeping confidential information contained
- 1. Know-your-client (KYC) & Suitability
- Calculators and Scratch Paper
- The Relationship the Rules Describe
- Clients Who Live Somewhere Else
- What KYC Has to Cover
- Tolerance, Capacity and Need
- Business Structures and Why They Change the Answer
- Writing It Down, and Having the Client Confirm It
- The Trusted Contact Person, and the Temporary Hold
- Who Owns KYC, and How Current It Has to Be
- What the Client File Holds
- Account Appropriateness
- The Account Types You Have to Compare
- What the Account-opening File Needs
- The Relationship Disclosure Document
- Keeping Confidential Information Contained
- The Welcome Package
- Product Due Diligence and Knowing the Product
- The Suitability Determination
- Unsolicited and Unsuitable Instructions
- Investment Actions
- Why Appropriateness and Suitability Are Separate Tests
- Monitoring, Triggering Events and Change
- Conflicts of Interest
- Outside Activities
- Personal Financial Dealings with Clients
- Standards of Conduct
- A Client, Worked End to End
- Twelve Ways to Lose Marks on This Element
- Fifteen Terms to Own
- One Item From CIRO's Practice Exam
Know-Your-Client (KYC) & suitability
Keeping confidential information contained
Firms hold information that would move a market if it leaked. The controls that stop it moving are called information barriers, sometimes firewalls. They separate the parts of the firm that hold sensitive information from the parts that could act on it.
Three areas are named in the syllabus, and each has a different reason to hold information. Investment banking knows about deals before the market does. Research forms views on issuers that clients will act on. Corporate finance sits close to both. The barriers stop a view formed on inside information from reaching a recommendation.
Two lists do the day to day work, and the exam tests the difference.
A grey list is a watch list. The firm may hold, or may come to hold, sensitive information about an issuer, so trading attracts heightened review and caution. It is a yellow light.
A is a stop. The firm cannot trade or solicit in that security, usually because a transaction is live and the conflict is real. It is a red light.
Cybersecurity and privacy belong in this section because they are the same duty with newer doors. Client information must be protected from unauthorised access, and personal information must be collected, used and kept within the limits the law allows. A stolen client list is a confidentiality breach that also breaks privacy law, and the exam may ask you to see both.
The analyze level matters here. You will not be asked to define a barrier. You will be asked to spot the moment when two duties collide, such as a research analyst being asked to join a marketing call about an issuer the firm is advising, and to say what the control is for.

