Portfolio manager client file documentation (OSC)
What examiners look for beyond the custodian packet
OSC exams commonly review whether advice was suitable and properly documented — not whether accounts were opened. The custodian portal collects trading forms; your client file still needs holistic evidence: financial circumstances, objectives, risk tolerance and capacity, and documented suitability rationale maintained by your firm.
Principals feel this gap when associates chase the same Notice of Assessment twice because nothing tracked completeness before the planning meeting.
Core file components
Exact requirements depend on registration category and firm policies, but PM client files commonly include:
- KYC questionnaires and supporting ID / address verification.
- Income, net-worth, and held-away asset documentation.
- Suitability rationale and investment policy statements.
- Conflicts and referral-arrangement disclosures where applicable.
- Timestamped client submissions and advisor review actions.
- Voice or written meeting notes supporting advice discussions.
Organize intake before the exam
Hivi-X standardizes household intake with reusable checklists, missing-item tracking, and exportable PDF packages for CRM or compliance folders. Data stays in Canada with self-hosted AI.
General information only — not legal, compliance, or investment advice. Consult qualified compliance counsel for your registration category.
FAQ
General information only — not legal, compliance, or investment advice. Hivi-X is document-collection software, not a registrant, KYC verifier, or AML screening service. KYC, suitability, and AML obligations remain with your firm. Consult qualified compliance counsel for your registration category.
Last updated 2026-07-09.