In introducing NI 31-103 the CSA noted:
“Compliance is a ;rm-wide responsibility.
We have sought to reinforce firm-wide responsibility
by setting out a general compliance obligation in the
Rule. Registered firms must establish and enforce a
system of controls and supervision that ensures the
firm’s compliance with all applicable requirements of
securities legislation. ;ese are not new requirements.
However, the Rule adopts a principle-based approach
to these requirements because experience suggests that
this is a better way to accommodate the diversity in
size and scope of our industry participants.”
IT’S ALL ABOUT DISCLOSURE