KYC update schedule not managed in the CRM
CIRO-registered investment advisors are required under National Instrument 31-103 to update client KYC information at a minimum every three years, or sooner when the advisor becomes aware of a material change in the client's circumstances. KYC update dates are typically tracked informally, and advisors are not proactively scheduling KYC review appointments at the appropriate interval. A CIRO examination finding that KYC records are out of date, or that the advisor cannot demonstrate a systematic process for scheduling KYC updates, creates a compliance deficiency that requires a formal response and remediation plan. The fix is a CRM configured to track the last KYC update date for every client and trigger a review booking at the appropriate interval.