RIBO client identification records Ontario

Answers are general operational information only — not legal, tax, regulatory, clinical, privacy, immigration, or professional advice. Requirements vary by matter, client, and regulator.

Frequently asked questions

Does RIBO require FINTRAC-style KYC on every personal auto file?

No universal RIBO rule says that. FINTRAC client-identification duties apply to specific reporting-entity activities (for example certain life-insurance situations). For day-to-day P&C personal lines, follow carrier/MGA requirements and your brokerage compliance manual — then keep the file producible for RIBO.

What ID documents belong in a personal-lines client file?

Typically government photo ID such as a driver’s licence or passport, plus whatever your carriers require for the risk. Exact lists vary — confirm with your compliance officer.

Should brokers keep both sides of a driver’s licence?

Many Ontario shops do, because the reverse can show address or class details used in underwriting. Follow firm policy and reject unreadable uploads.

Can we use an Ontario health card as ID?

Health-card collection is restricted in Ontario for many non-health purposes. Prefer other government photo ID unless counsel and firm policy clearly allow a specific use.

How long should ID records be retained?

Reg. 991 record-retention themes (commonly discussed as at least the six-year period before the most recent fiscal year-end for required records) plus carrier and firm policy. Confirm with your principal broker.

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