Staff Notice 31-368: documenting meaningful KYC updates

What changed under client-focused reforms

Joint CSA/CIRO Staff Notice 31-368 is part of the client-focused reforms phase that tightened expectations around KYC updates. The practical shift for boutique portfolio managers and planning practices: you need a record that shows what changed in the client's circumstances and what you discussed — not just a dated field in Wealthbox.

Checkbox-only annual reviews are a common exam finding. Advisors know they spoke with the client; the file does not prove it because notes lived in email or a personal device.

What "meaningful interaction" looks like in practice

Regulators evaluate whether the update reflects current client information and documented engagement. Operational artifacts often include:

• Updated risk tolerance and objectives questionnaires with client responses.
• New tax returns, Notices of Assessment, or statements reflecting life changes.
• Meeting summaries or call recaps tied to the KYC update date.
• Checklist items marked received and advisor-approved on the firm-controlled record.

How checklists and notes help — without replacing compliance

Hivi-X lets you attach an annual KYC refresh checklist to the household file. Clients upload updated documents through the my-id.ca portal; your team approves each item; voice notes and self-hosted AI summaries capture discovery-call recaps against checklist lines.

Export a PDF package for internal file review or CRM upload. Hivi-X does not determine suitability or replace your compliance manual. This page is general information, not legal or compliance advice.