Clients who live somewhere else
- 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
Clients who live somewhere else
Clients move. A snowbird spends five or six months a year in Arizona and keeps a Canadian account. A client takes a job in Texas and keeps the house in Ontario. A client retires to Portugal and calls you from a different time zone.
Residence changes which rules reach the account. A client who becomes a resident of the United States drags tax reporting obligations onto the account, and the firm's ability to serve that client may narrow or end. A client who moves to another province changes the securities rules that apply and may change their tax position.
The wrong answers in a scenario are always the two extremes. "Close the account" ignores the client. "Carry on as before" ignores the law. The right answer is a process:
- Identify that the change is happening, and when.
- Tell the firm, because the firm carries obligations the representative does not.
- Follow the firm's written procedure for that jurisdiction.
- Document the advice the client received, in their words and yours.
Part year residence is its own trap. Six months in Arizona is not a change of residence in the ordinary sense, but it is enough to trigger cross border requirements. Ask about time spent outside Canada at account opening, and ask again when a client mentions a second home.

