The Canadian Securities Administrators (CSA) have now implemented amendments to National Instrument 31-103 Registration Requirements Exemptions and Ongoing Registrant Obligations (NI 31‑103) and to its Companion Policy 31‑103 CP as amended (the Policy Statement). This is the second phase of its long standing project on enhancing a registrant’s relationship with its clients, called the Client Relationship Model (CRM) Project. This second phase (Phase II) mainly expands cost and registrant compensation disclosure and introduces performance reporting requirements. These changes, while strongly debated with members of the industry as to the time and expense they entail, have not been altered substantially by the CSA since their latest proposal last year, except as to the transition period over which they will be implemented. Certain of these changes will come into application on July 15, 2013, while others will be introduced on July 15, 2014, 2015 and 2016.


Transition periods for Phase II amendments cover, as discussed, one, two or three years from adoption of the amendments.

The table below sets out the transition periods for the key amendments discussed above.

Key Provisions


  • All new requirements not stated elsewhere in this table

July 15, 2013

  • RDI Benchmarks, s. 14.2(2)(m)
  • Scholarship Plan Dealers – Disclosure of Impact of Plan Term Breaches, s. 14.2(2)(n)
  • Pre-trade disclosure of charges, s. 14.2.1
  • Trade confirmation – Disclosure for Debt Security Transactions, s. 14.12(1)(b.1)(c.1)

July 15, 2014

  • Determining market value, s. 14.11.1
  • Account statements and additional statements, s. 14.14
  • Position cost information, s. 14.14.2
  • Securityholder statements, s. 14.14.2
  • Scholarship plan dealer statements, s. 14.16

July 15, 2015

  • Disclosure by investment fund managers, s. 14.1.1
  • Determining market value – adding the requirement for investment performance reporting, s. 14.11.1(3)
  • Trade confirmations – adding deferred sales charge information, s. 14.12(1)(c)
  • Annual summary of charges and compensation, s. 14.17
  • Investment performance reports, s. 14.18, s. 14.19 and s. 14.20

July 15, 2016

Our bulletin provides further details on its significant industry impact.