One of the greatest challenges of implementing CRM II is the very tight deadlines, “given the extensive and far-reaching changes needed to be made to core systems and many client-facing documents to comply with the mandated performance reporting rules, and disclosure of advisor compensation and fees,” says IIAC president and CEO Ian Russell.
So he urges regulators “to be mindful of the enormous commitment of resources to this project, and to limit additional rule-making during this rule implementation period to absolutely essential initiatives.”
Russell also emphasizes the need for effective oversight, especially now that CSA has developed a second set of rules.
To help support member firms, IIAC has formed six work streams, each made up of teams of experts from member firms, to collaborate on solutions and drive the rule implementation process forward.
These work streams include teams focused on identifying priority implementation problems, dealing with the inter-firm transfer of securities, working with FundSERV and non-FundSERV-using fund companies to address “off-book” funds, scoping out the reporting requirements, dealing with securities valuation and organizing communication with individual IIAC firms on implementation progress.
The groups will communicate on an ongoing basis with the regulators to keep them up-to-date, specifically in what’s working and what’s not.