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Advisor Compliance Checklist



Section 1:
Advisor Disclosure Obligations


  • To comply with industry guidelines/standards
  • Must be provided prior to the sales transaction

**Regulatory requirement of all licensed advisors


The client must have clear information about:


  1. Any industry-related licence(s) you hold
  2. Companies you represent
  3. Nature of your relationship with the Companies
  4. How you are compensated
  5. Additional compensation you may receive (e.g. volume bonus; travel incentives)
  6. Any Conflict of Interest
  7. Client’s right to ask for more information

**Note: CLHIA also offers guidance for group products

View Resources on HUBLink




Risk Assessment Checklist


Have you reviewed the CLHIA reference document “Advisor Disclosure” for the specific requirements of the jurisdictions you are licensed in?

Yes No

Do you provide your Disclosure document to all clients?

Yes No

Do you have a client signed Disclosure document in all client files?

Yes No

Have you included information pertaining to other business activities in your personal Disclosure document?

Yes No

Section 2:
Managing Conflicts of Interest Obligations


  • Disclosure of actual, potential or perceived conflicts of interest
  • Interest of the client must be placed ahead of the advisor
  • Product must be suitable for the client’s needs
  • To comply with industry requirements / standards

View Resources on HUBLink


Risk Assessment Checklist


Have you provided information which the client needs to assess whether a conflict may influence the advice given?

Yes No

Do you disclose any real or potential conflicts of interest on an on-going basis?

Yes No

Have you considered and included any perceived conflicts associated with other occupations or business activities?

Yes No

Have you considered and included any perceived conflicts associates with personal or professional relationships with the client?

Yes No

Section 3:
Product Suitability Obligations


  • To help your client make an informed and confident purchase decision
  • To comply with regulatory / industry / company requirements and standards

View Resources on HUBLink


Risk Assessment Checklist


Do you follow the “Approach”?

Yes No

Do you understand the products recommended to clients?

Yes No

Have you provided your client sufficient information to make an informed and confident purchase decision?

Yes No

Section 4:
Needs-Based Selling Obligations

  • To comply with regulatory / industry/ company requirements and standards
  • Identify and assess the client’s insurance needs in order to recommend a product that is suitable and meets the needs of the client
  • Document the reasons for recommendations made

The Approach – General Principle:
The recommended product or service must be appropriate for the needs of the client as determined by a needs assessment and/or as identified by the client.

  1. 1. Provide Disclosure to the client
  2. Set Client Expectations regarding the advisor/client relationship
  3. Conduct a reasonable Fact Find
  4. Conduct a Needs Assessment
  5. Provide client with Recommendations & professional Advice
  6. Provide written explanation of recommendation – Reasons Why
  7. Provide Product Information to the client

View Resources on HUBLink


Risk Assessment Checklist


Do you follow the sales process outlined within the “Approach”?

Yes No

Have you conducted a fact find on the client?

Yes No

Have you gathered and documented sufficient information from the client to identify the life insurance needs?

Yes No

Have you reviewed and considered existing policies or contracts held by the client?

Yes No

Have you engaged the client in the selection process?

Yes No

Do the product features fit the need of the client?

Yes No

Have you provided the client with a written summary and explanation of the recommendation?

Yes No

Section 5:
Policy Replacement Obligations

  • Disclose all information needed to ensure client has a good understanding of the product recommend and the impact of proposed replacement
  • Ensure policy replacement is in the best interests of the client
  • To comply with provincial regulations

View Resources on HUBLink


Risk Assessment Checklist


Do you understand the provincial replacement disclosure regulations?

Yes No

Have you provided the client with the replacement declaration?

Yes No

Have you provided the client with a written explanation of the advantages and disadvantages of replacing their existing life insurance policy (prior to starting a new application for coverage)?

Yes No

Do you have a copy of the client signed documents in your client file?

Yes No

Have you reviewed the existing coverage to ensure your understanding of the policy to be replaced?

Yes No

Section 6:
Record Keeping Obligations

Files must be current, correct, complete, consistent & contemporaneous

  • Client signed Disclosure/Engagement Letter
  • Consent to collect personal information
  • Fact Find
  • Risk Assessment / ID verification
  • Illustrations
  • Needs Assessment/Recommendations
  • Replacement forms
  • Reasons Why Letter
  • Policy Delivery Receipt
  • Consent to communicate electronically (CASL)
  • Notes relating to sales process and on-going service

View Resources on HUBLink


Risk Assessment Checklist


Do you have consistent process for documenting client interactions?

Yes No

Does your record keeping process cover all recommended elements of appropriate documentation?

Yes No

Have you obtained consent to retain any personal information collected from the client?

Yes No

Have you obtained consent to communicate with your client electronically regarding your services and any new products you may recommend?

Yes No

Section 7:
Anti-Money Laundering and Anti-Terrorist Financing Obligations

  • To help detect and deter money laundering and the financing of terrorist activities
  • To comply with AML/ATF regulation  Appoint a Compliance Officer
  • Written policy & procedure  Conduct a Risk Assessment (every 2 years)
  • Complete a Self-Assessment (every 2 years)  On-going training

View Resources on HUBLink


Risk Assessment Checklist


Do you have a written AML/ATF compliance regime?

Yes No

Have you completed a risk assessment of your clients and your business?

Yes No

Have you completed a risk assessment of your compliance regime (self-assessment)?

Yes No

Do you understand your obligations?

Yes No

Have you undergone training and conducted training for any staff members?

Yes No

Section 8:
Privacy Obligations

  • Protect client’s information
  • To comply with federal and provincial privacy laws
  • Appoint a Compliance Officer
  • Written policy & procedure
  • Privacy Breach process
  • Testing of policy & procedure
  • On-going training

View Resources on HUBLink


Risk Assessment Checklist


Do you have a written privacy program?

Yes No

Have you and your employees completed privacy training?

Yes No

Do you communicate personal information in a secure manner?

Yes No

Do you provide clients with a copy of your privacy statement?

Yes No

Do you obtain client consent to collect and retain personal information?

Yes No

Have you reviewed the privacy practices in your office?

Yes No

Do you have secure file storage measures in place?

Yes No

Section 9
Canada's anti-spam legislation Obligations

  • To obtain express consent from all clients to communicate electronically
  • To comply with CASL rules and legislation

View Resources on HUBLink


Risk Assessment Checklist


Do you communicate products and services to clients electronically?

Yes No

Have you obtained written consent from all clients?

Yes No

Do you have an “unsubscribe” mechanism in place?

Yes No

Section 10
Do Not Call Obligations

To comply with the CRTC National Do Not Call Legislation

View Resources on HUBLink


Risk Assessment Checklist


Are you engaged in telemarketing?

Yes No

If yes, is the telemarketing exempt or non-exempt?

Yes No

Is the telemarketing being done on behalf of the advisor or on behalf of a company?

Yes No

Section 11
Errors & Omissions Obligations

  • Understand your policy
  • Licensing requirement in most provinces
  • Carrier requirement as part of your contract
  • Protection of advisor assets in the event of a claim

View Resources on HUBLink


Risk Assessment Checklist


Do you have E&O coverage?

Yes No

Do you understand your policy?

Yes No

If you are incorporated, does your policy cover the activities conducted on behalf of your agency?

Yes No

Has your E&O coverage been continuous (no gaps in coverage)?

Yes No

Section 12
Education & Training Obligations

  • C.E. Credits
  • License requirement in many provinces

View Resources on HUBLink


Risk Assessment Checklist


Has your E&O coverage been continuous (no gaps in coverage)?

Yes No

Do you attend educational classes to stay informed of your obligations?

Yes No