Portfolio managers and compliance officers amending their relationship disclosure information (RDI) documents to meet changes introduced in the new client relationship model (CRM 2) should think of the new form as a marketing tool, according to legal experts speaking at the Portfolio Management Association of Canada’s (PMAC) Toronto Compliance Forum on Wednesday.
“We encourage people to think beyond just seeing it as a regulatory document,” says Rebecca Cowdery, partner, Borden Ladner Gervais LLP, who spoke at the conference. “It is a way to really get to your clients and it is a way to differentiate.”
An effective RDI document goes beyond the “laundry list” of requirements listed in CRM 2, says Prema Thiele, partner, Borden Ladner Gervais, who also spoke at the event, by including detailed summaries of services and the portfolio manager’s philosophy on things such a conflicts of interest.
“[The RDI document is] a very good description of all aspects of your business in some detail and perhaps an introduction to some of the key people,” says Thiele. “So use it as a marketing document.”
As a marketing tool it’s also acceptable to place the RDI form on the portfolio manager’s website, says Cowdery. However, if the RDI document is placed on the company’s website it must be constantly updated and a hard copy needs to be handed out to prospective clients before an account is opened.
The drafting of the new RDI document is also a good time to change how that form is sent out to clients, says Cowdery. “Think about getting the client to consent to some form of electronic delivery,” she says. “This is the perfect opportunity.”