Country Manual Products – Update
Canada
BRP has updated its Country Manual Products for Canada
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Definitions & Concepts, Regulatory Overview and Behaviour Template
The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.
Material changes
The changes/modifications are as follows:
Finally, the provision of publications and other marketing material referring to specific financial products (such as newsletters, teasers, presentations, summaries, term sheets, factsheets, offering documents and prospectuses) is generally not deemed distribution in Canada if it is made on a generic basis and provided to multiple investors. However, please note that this activity is deemed distribution if it is based on the specific investment profile of one recipient. Accordingly, the provision of such information/reports made on a personalised basis, irrespective on the type of solicitation, should be avoided. The CM P BT therefore now provides the answer “NO” in the relevant scenarios.
In alignment with the Country Manual Private Banking (CM PB), the provision of macroeconomic information/reports and investment research and financial analysis documents/reports on a cross-border basis into Canada (remote) and outside of Canada (at source), irrespective of the type of solicitation, is regarded as a regulated investment service only if the information is not tailored to the needs of the client. Accordingly, the Country Manual Products Behaviour Template (CM P BT) therefore now answers the relevant scenarios with “Grey zone/YES”.
In further alignment with the CM PB, please note the provision of macroeconomic information/reports and investment research and financial analysis documents/reports onshore in Canada (at target) should be avoided. The CM P BT hence answers the relevant scenarios with “Grey zone/NO”.
Non-material changes
Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
For more information, please contact us: info@brpsa.com
Geneva, October 7th, 2024