I think it’s a combination of everyday challenges and big picture
thinking. On a really micro scale, if you spent 20% of your time on
administration before and 25% reporting to your client, switching to
Exempt Logic means that now you save the 25% spent on reporting
by using Exempt Logic to complete your administration. Then you
add in the benefits of being able to transact transparently with
issuers - plus the ability to ensure every transaction is compliant
with the exemption criteria under NI 45-106 and NI 31-103 and that
a completed KYC form accompanies every trade along with a trade
confirmation to the client.
When you stop to see the problem from all sides - issuer
and dealer - and consider what has worked in other industry
categories, you really start to understand the risks in not having a
program like this in place.
Dealers in the exempt market face growing consolidation
pressure as costs mount to meet the new regulatory requirements
associated with compliance, administration and financial
reporting. Infrastructure is what our industry needs to foster
growth and provide dealers of all sizes and specialties an
opportunity to succeed. Exempt Logic is a small part of that
The simple answer is that you cannot enter a non-compliant
trade into Exempt Logic.
Each dealer’s KYC is uploaded into our system. Every
transaction has to have an associated KYC attached to it for the
system to proceed from draft to final. In that process, a chief
compliance offer is alerted that a trade is pending approval
and requires their review. Trade won’t be processed as a final
trade until every requirement is met, tailored to the compliance
requirement of each subscriber’s jurisdiction. This will be a boost
to the efficiency of the dealer’s compliance program.
Exempt Logic operates in real time. In fact, the only
delay comes in physically sending paperwork and a cheque.
As transactions are entered into the system, they move from draft
to pending to final - in real time status. Administrators, dealing
representatives, dealers, and issuers can see exactly where things
are at, right as the data is entered.
If you’re working with an issuer who is not on the platform,
we offer a Third Party Mode. This is a growing area for us, but
it shouldn’t stop anyone from using Exempt Logic. Right now,
Exempt Logic offers manual updates to report on offerings where
an issuer is not on the platform.
When dealers need to report on investments that pay a yield
or distribution, we confirm with the issuer that those distributions
were in fact made and enter them into the database on behalf of the
issuer’s offering, so they are reflected in dealer statements accurately.
The securities regulatory framework in Canada is a patchwork
between provinces. Regulations depend on where the subscriber
lives and what exemptions are being relied upon by the issuer.
The logic we’ve built into Exempt Logic manages this patchwork
so that transactions are more compliant for any dealer or issuer
and the language in the regulations is built right into our program.
We’ve made sense of it.
Exempt Logic is the most comprehensive solution in the
market today. As time goes on, it will only become more difficult
to deal with reporting and compliance issues and regulatory
oversight will only become more burdensome. Making the switch
to Exempt Logic will help you stay on top of it.
Why should companies consider a switch to
Exempt Logic? 11
What are the needs within the exempt market? 12
How does Exempt Logic help to ensure compliance? 13
What does ‘real time’ mean in Exempt Logic? 14
What about issuers who are not using Exempt Logic? 15
Where did the name ‘Exempt Logic’ come from? 16
Why is this platform necessary? 18
How does Exempt Logic deal with issuers
who make distributions? 17