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Is use of NRD mandatory?
The use of the NRD system has been mandated by Multilateral Instrument 31-102 National Registration Database. This rule requires that certain registration information and registration fees be submitted using NRD. NRD is mandatory for all firms registered and seeking registration, no matter what their registration catagory is.
Are we required to submit supporting documentation to all the jurisdictions in which an individual is applying for registration?
This is not required. Supporting documentation should only be sent to the "lead jurisdiction" (defined below). The lead jurisdiction will record the receipt of the required supporting documents so that other regulators are aware it has been submitted. Generally, the non-lead jurisdictions will not ask for duplicate documentation, though they may request any information they deem necessary.
In non-delegated jurisdictions - that is, in jurisdictions where the local CSA member has not delegated its registration activities to the IIROC - IIROC Member firms will be required to send copies of the supporting documents to both the CSA lead commission and the IIROC.
The "lead jurisdiction" is defined as follows.
For individuals - the lead jurisdiction is based on that person's current residential address. If the individual resides outside of the participating jurisdictions (i.e. foreign), the lead jurisdiction is determined by a "weighting" of the provinces/territories in which the individual is applying to register.
The weighting of the provinces/territories is as follows:
3. British Columbia
7. Nova Scotia
8. New Brunswick
9. Newfoundland and Labrador
10. Prince Edward Island
11. Northwest Territories
For firms - the lead jurisdiction for a firm is based on its head office address. If the firm's head office is outside of the participating jurisdictions (i.e. foreign), the lead jurisdiction is determined by a "weighting" of the provinces/territories in which the firm is applying to register. The weighting of the provinces/territories is as noted above.
Do we need to complete Form 33-109F4 for non-registered individuals?
Yes. All non-trading, non-advising partners, directors and officers are required to submit a completed Form 33-109F4 through NRD.
Do I have to keep a paper copy of my registration form?
No. Regulators won't expect you to produce copies of anything that is stored on NRD. However, firms and individuals may choose to maintain paper copies of the information.
For those registration processes that remain paper-based (such as firm registrations or submission of supporting documents), will we need to continue to submit information separately to each jurisdiction?
Yes. There is no other way for the regulators in each province to view and evaluate the applications, since there is no centralized location for the data.