If you’re an IIROC registered rep approved to work from home, should your home be reported as a business location?
A business location, as defined in rule 1.1, is “a physical location where, on a regular and ongoing basis, at least one of a dealer member’s employees or agents conducts business that requires corporation approval or registration under securities legislation.”
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In a rules notice, IIROC reminds members that yes, a home should be reported as a business location if the work-from-home (WFH) arrangement is regular and ongoing and any of these factors apply:
- more than one rep conducts registerable activities at the home on behalf of the dealer member;
- the home is held out to the public — with signs, business cards or the like — by the rep or dealer member;
- the rep meets with clients at the home; or
- the rep maintains books and records at the home that aren’t duplicated at the office.
In light of the popularity of working from home, IIROC proposes in the notice that dealer members maintain a list of those with approved WFH arrangements — regardless of whether or not the dealer member has notified IIROC of the home as being a business location, under rule 40.8.
Business Compliance Conduct could review the list maintained by dealer members to determine which, if any, WFH arrangements should be examined to test whether the dealer member has notified IIROC of all appropriate business locations.
IIROC says its compliance approach to working from home will consider whether the dealer member’s compliance record suggests inadequate supervision of WFH arrangements.
Read the notice here.
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