IIAC Activity Update February 2015

* designates a new or amended entry

CSA - SRO Issues

*Cooperative Capital Markets Regulatory System

The IIAC submitted comments on the draft Provincial Capital Markets Act and the Capital Markets Stability Act in December 2014. The IIAC continues to support the objectives of this initiative and the proposed legislation. The IIAC submission highlighted the difficulty of fully assessing the draft legislation in the absence of detailed regulations. Further, we expressed concerns that the transition and implementation not result in additional costs or impose undue regulatory burdens on market participants. We also raised questions regarding how participating jurisdictions will interact with non-participating jurisdictions. The IIAC plans to comment on the draft regulations when they are released in the spring.

IIROC Consultation on Proficiency Assurance Model (Options for Other Education Providers)

The agreement between IIROC and CSI to provide licensing courses and examinations expires in January 2016. As a result, IIROC released a Consultation Paper evaluating the current model and examining possible alternative approaches. The IIAC’s Proficiency Assurance Model Working Group responded to the Consultation Paper which will assist in informing IIROC in its deliberations.

*Client Relationship Model (See also Operational Assistance – Best Practices and Tools below)

The IIROC CRM2 Rules for 2015 and 2016 have now been finalized. The IIROC CRM2 Rules will provide dealers with the opportunity to apply for an exemption if certain criteria are met for client-name accounts. The IIROC Rules do not address the position cost issues related to grandfathering and client elections. The CSA is contemplating these issues, and a final rule determination is expected soon. The IIAC is still seeking a CRM2 rule adjustment that would allow a calendar year option for CRM2 reporting to meet calendar-year client preferences without accelerating and adding risk to development plans. The CSA is

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reviewing the alignment request. Extensive work by IIAC CRM2 committees continues. All retail and integrated IIAC dealers are encouraged to participate in an IIAC committee to ensure they are aware of changes currently under consideration.

Proposed Amendments to the Order Protection Rule (OPR)

IIAC responded to the CSA’s Proposed Amendments to NI 23-101 Trading Rules, which were designed to address certain costs and inefficiencies related to the current application of the OPR. The proposed amendments would impose a 5% market share threshold before marketplaces would be designated as “protected marketplaces”, impose interim trading fee caps, address concerns related to market data fees, and create a pilot project to review the maker-taker fee model. The Association’s comments expressed general support for the proposed amendments, provided they are implemented as a package to address the myriad of issues.

Proposed Guidance on Marketplace Thresholds

IIAC responded to IIROC’s proposed new Guidance regarding the establishment and operation of price and volume thresholds by each marketplace in Canada, which would supplement other IIROC initiatives for controlling short term, unexplained price volatility and risks arising from electronic trading. The guidance reflected many of the suggestions provided by IIAC in the previous request for comments.

Short-term Debt Prospectus Exemptions In August 2014, the IIAC was invited by the CSA to provide additional comments on revisions made to the Proposed Amendments to NI 45-106 Prospectus and Registration Exemptions Relating to the Short-term Debt Prospectus Exemption and Proposed Securitized Products Amendments. The majority of the revisions reflected concerns the IIAC had expressed in its April 2014 Response Letter. The IIAC’s latest comments focused on clarifying requirements and ensuring that the implementation and transition period will provide firms with sufficient time to implement the proposed requirements without market disruption. Proposed New Prospectus Exemptions

The IIAC responded to proposals by the OSC and other securities commission to create or amend proposed prospectus exemptions intended to facilitate capital raising by businesses at different stages in their development. The four exemptions included:

1. An offering memorandum exemption,

2. A family, friends and business associates exemption,

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3. An existing security holder exemption, and

4. A two-tiered crowdfunding exemption.

The Association expressed serious concerns that the proposals differed among jurisdictions, leading to an inconsistent, confusing and inefficient patchwork of exemptions that could hamper capital raising efforts. IIAC was also critical of the proposed crowdfunding exemptions as they pose serious risks to investor protection.

IIROC Issues Proposed Guidance Respecting Underwriting Due Diligence

IIAC submitted comments on Proposed Guidance Respecting Underwriting Due Diligence. The Association is concerned that the Guidance, which is not intended to set minimum or maximum standards or new legal obligations, articulates very specific practices using terms such as “key principles” in describing practices and suggestions for underwriting due diligence. IIAC expressed concern that the guidance would effectively create a regulatory checklist for review, and provide the basis for increased legal liability.

*IIROC Debt Securities Transaction Reporting Rule

On October 30, 2014 IIROC published its Debt Security Transaction Rule (Rule 2800C). The final rule reflects some of the comments previously submitted by the IIAC. Under the new framework, Dealer Members will be required to report to IIROC, on a post-trade basis, debt security transactions they execute and those of their affiliates that are Government Securities Distributors (GSDs). The framework has been approved by the Canadian Securities Administrators. By November 2015, all IIROC members that are GSDs will be required to commence reporting into IIROC. All other IIROC members will be required one year later. A proposed fee-model has also since been issued by IIROC outlining how IIROC envisages recouping its cost for maintaining the system

CSA Review of the Proxy Voting Infrastructure

The IIAC is actively participating in the CSA Proxy Voting Infrastructure Technical Working Group, which was created in June 2014 to discuss and develop solutions to specific technical issues that would improve the proxy voting infrastructure in Canada. The IIAC is also working with the CSA as it continues its review of the proxy voting infrastructure to provide more detailed information about intermediary processes for identification of shareholder voting entitlements. The OSC has stated that one of its priorities for 2014 was to complete its review of the proxy voting infrastructure, which could potentially result in further recommendations for industry best practices or policy changes, in 2015. IIAC will continue to participate in these ongoing discussions.

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IIROC Proposed Provisions for Order Execution Services as a form of Third-Party Electronic Access to Marketplaces The Association responded to IIROC’s proposal to implement specific supervision and client identification requirements relating to Order Execution Services account activity. The objective of the proposals is to achieve consistency in regulatory and supervisory requirements across all forms of third-party electronic access to marketplaces. IIROCs final regulation incorporated many of IIAC’s suggestions, and subsequently granted IIAC’s request for an extension for firms requiring an extension for implementation.

CSA Modernization of Investment Funds

The IIAC responded in August 2013 to the CSA’s 2013 request for comments on the proposed modernization of investment fund product regulation amendments, which would have significantly affected members’ closed-end fund business. The IIAC supported governance changes, but disagreed with new investment restrictions and requested the CSA to clarify that no changes would be made for the period of time necessary to consult fully on proposed limits and alternative funds, after which time any new regulation should grandfather then existing funds. The CSA issued a final rule in June 2014 (with a September effective date). As the IIAC requested, the issuer concentration restriction, illiquid asset restrictions, and proposed organizational costs amendments were not enacted (although may be republished for comment with the re-publication for comment of the alternative funds proposals and interrelated investment restrictions, at a future date.

Unregistered Foreign Dealers in Foreign Listed Derivatives

Following an IIAC submission and subsequent discussions, the OSC published Staff Notice 33-744 dated September 18, 2014 that provides an interpretation of the unsolicited trade exemption and the hedger exemption available to foreign dealers in connection with trades in foreign listed derivatives. IIAC believes this severely narrows the scope of permitted activities by unregistered dealers. In addition, amendments to National Instrument 31-103 released October 16 also include the removal of the “non-solicitation exemption” for trades in exchange contracts in Alberta, British Columbia, New Brunswick and Saskatchewan. These were previously widely used by U.S. FCMs to deal with Canadian investors. IIAC will continue to make representations to other CSA jurisdictions where similar exemptions are still available.

Fiduciary Standard in Canada

The IIAC submitted a response to the CSA’s consultation paper regarding the appropriateness and feasibility of introducing a statutory best interest duty for advisors in Canada. The IIAC believes that Canada has been proactively advancing its securities regulatory regime and that CRM will address investor protection concerns. CRM should be

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fully implemented and evaluated prior to the consideration of new policy initiatives. In addition, a cost benefit analysis must be conducted. The IIAC also believes a best interest standard could result in potential unintended negative consequences for investors and the industry. The IIAC and IFIC worked with Torys LLP on a research report that examined what the actual standards for advisors are in other jurisdictions. The report concluded that Canada’s regulations are equal to or more stringent than what other jurisdictions have labeled a fiduciary standard. The report was provided to the CSA. The CSA recently released a summary of the comments it received on its consultation paper and it stated in the next few months it would decide what, if any regulatory actions it may take.

OTC derivatives reform In line with Canada’s G-20 commitments, the CSA initiated a reform of OTC derivatives in 2010. The reform is expected to cover clearing, trade reporting, trading, capital and collateral and registration. Although the reform initiative primarily targets the swap market from which IIAC members are largely absent, they will apply to some members involved in other types of – mostly retail – OTC derivatives and may impact listed derivatives. IIAC and the Derivatives Committee have consistently argued that our members’ activities in OTC derivatives do not raise any systemic risk issues and that IIROC already provides a proven regulatory framework. We have therefore submitted that they should be exempted form the CSA rules. We have also argued that a new registration regime is not required for derivatives and that, at the very least, listed derivatives should be excluded form any proposed new regime. IIAC will continue to lobby regulators for exemptions from OTC derivatives rules on the basis that IIROC provides equivalent regulation. New Issues Not Available in Quebec Section 40.1 of the Quebec Securities Act mandates the translation of all prospectuses filed in Quebec as well as all documents incorporated by reference. Because of this obligation, half of new “national issues” are not filed in Quebec. As a result, Quebec investors are largely excluded from the primary market. To address this problem, IIAC has recommended the adoption of the “European approach” of translating only a summary of the prospectus. This issue will be pursued as part of a broader project of addressing the structural issues that have contributed to a collapse of the IPO market in Quebec. IIAC will be collaborating with other private sectors participants and government entities on that agenda. Government and Tax Issues

*Financial Planning

The Ontario government published a request for comments examining the merits of more tailored regulation of financial planners. The IIAC prepared a response in January 2014,

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which included general support for additional clarity and standardization for the provision and supervision of financial planning in the industry. However, the IIAC made it clear that individuals who are members of an SRO should be able to offer financial planning services without an additional requirement to join another SRO for financial planning as this would lead to unnecessary duplication and redundancy.

*Retirement Savings Reform – Pooled Registered Pension Plans (PRPPs) and Ontario Retirement Pension Plan (ORPP)

The federal government introduced PRPP legislation and regulations in 2012 that apply to federally regulated firms. PRPPs are retirement plans with the flexibility of group RRSPs and the payroll-tax-exempt status of pension plans. They are being offered by insurance companies and banks, and to compete with group and individual savings plans. In January 2014, the IIAC sent a letter to the Ontario Finance Minister in response to a consultation paper on PRPPs released by the Ontario Ministry of Finance recommending that, should the province implement PRPP-equivalent legislation, it should provide for an advice-inclusive option and allow equal portability between PRPPs and RRSPs; as well, the province should press the federal government to press for elimination of the CPP and EI (which do not apply to PRPPs) on employer and employee contributions to Group RRSPs. B.C., Saskatchewan, Alberta, and Quebec have now introduced or finalized (Quebec) varying forms of legislation to establish PRPPs in these jurisdictions and a number of provinces are examining an expansion in or complementary option to the CPP. The IIAC has sent a response to the Alberta Government on its PRPP program.

In December 2014, the Ontario government released a consultation paper and introduced legislation that would commit the government to establishing an Ontario Retirement Pension Plan (ORPP) by January 1, 2017. The IIAC will be responding to this consultation paper, urging the Ontario government to reconsider its position and introduction of the ORPP, as it would have serious negative consequences for existing retirement savings programs and the financial services industry generally. Other less costly and more effective solutions and improvements to existing programs should be implemented instead of creating another new retirement savings plan.

B.C. Wills, Estates and Succession Act

The IIAC wrote the B.C. government to request it defer enforcing irrevocable beneficiary provisions (sections 87 and 88) of the British Columbia Wills, Estates and Succession Act as they apply to registered retirement-savings plans, tax-free savings accounts and other registered plans. The government’s efforts were to establish consistency across insurance and other products, and to simplify estate-planning. However, given differences between pure insurance and registered plans, the IIAC argued that the well-intentioned changes would leave plan-holders or beneficiaries, in many cases, worse off. The IIAC asked for further discussion. , and received a response (as did the Canadian Bankers Association)

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saying that the industry should have responded earlier. The IIAC is continuing to work on this issue with the CBA. The CBA has now received a letter saying that the government will make no change; the IIAC is awaiting a similar letter and then will discuss further action.

Federal Budget 2015

The IIAC sent its pre-budget submission to the House of Commons Standing Committee on Finance, and appeared before the Committee in October 2014 to present its recommendations. The IIAC’s recommendations focused on promoting capital-raising by lowering the capital gains tax, studying a U.K. model for supporting early stage companies and pressing for the elimination of payroll tax on Group RRSPs to help businesses and put them on a level playing field with PRPPs and other pension plans. . The Finance Minister announced that the 2015 federal budget will not be tabled before April 2015.

*High-Value TFSAs and Small Borrowings

The IIAC is continuing to work on a high-value TFSA matter that leaves dealers exposed to considerable risk of loss. The IIAC submitted a letter to Finance to request that the liability of industry members be limited through an amendment in to the Income Tax Act. Also, clients are being penalized for minor inadvertent short-term borrowings (e.g., when a client’s account is in a negative balance one day due to a settlement mismatch). IIAC staff met with the CRA and Finance in late January 2014 and is following up regularly on this important issue. The IIAC wrote to Finance and the CRA, as both legislative and administrative solutions are required, in the summer of 2014, and raised the issue in an October meetings with the CRA and Finance to pursue this issue further. The issue was raised with Deputy Finance Minister Paul Rochon in November 2014.

Goods and Services Tax/HST Review The federal government has begun research on the application of GST to financial services, which has gone un-reviewed in the 20 years since the GST’s inception. IIAC met with, and made submissions on this matter. A Finance discussion paper presented proposals and the IIAC is preparing a response is expected in the fall or winter.

Goods and Services Tax Change: Trade Execution Fees

In February 2011, an IIAC member advised that alternative trading systems Alpha and CNSX had obtained a CRA ruling that trade execution was GST-exempt, despite TSX execution fees having been taxable since the GST’s inception in 1991. IIAC staff followed up with the TSX representative, who said that that the TSX would pursue a similar ruling. A favourable ruling has been received and is being used to pursue favourable treatment of similar MX fees. There is a concern relating to the GST treatment of certain fees charged by carrying to

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introducing brokers for trade execution. A small IIAC task force was discussing this issue and one party has changed its position. A note is being prepared and sent to the other parties.

*U.S. Tax Reporting and Withholding -FATCA

In June 2014, the Canadian government passed legislation and published detailed guidance to implement the intergovernmental agreement (IGA) with the United States to facilitate the provisions of the Foreign Account Tax Compliance Act (FATCA) in Canada. All Reporting Canadian FIs (which will include all IIROC registered investment dealers) should have registered and obtained a GIIN by December 31, 2014. New FATCA compliant W-8BEN forms are also available on the IRS website, along with detailed instructions on how clients should complete the forms. These new forms should be in use for new account opening as of January 1, 2015. IRS Notice 2014-33 and the Canadian guidance allowed FIs to continue to document entities as per existing procedures (W-8BEN and/or KYC) until December 31, 2014, however, the FATCA status of those entities must be documented by the end of the due diligence deadline for pre-existing entity accounts (i.e. by June 30, 2016).

In late June 2014, the IRS also published the revised Qualified Intermediary (QI) Agreement, which has been amended to align with the FATCA requirements. All IIROC dealers in Canada are currently QI compliant, and will have to carefully review and consider changes required to comply with the revised QI Agreement (both Carrying Brokers that act as QIs and the Introducing Brokers that must implement certain account documentation and due diligence requirements). The standardized IIROC IB-CB Agreements which currently contemplate U.S. tax withholding and QI will require changes to incorporate the new QI Agreement and FATCA provisions. IIAC is working with members, outside consultants and IIROC to facilitate these revisions to the IB-CB Agreements.

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* OECD Common Reporting Standard (CRS)

In summer 2014, the OECD published a final version of the framework for a Common Reporting Standard (CRS), which would require multilateral information sharing of non-resident tax information (similar to FATCA) among all countries that adopt the CRS and implement local legislation to implement the Standard. In October 2014, a group of “early adopter” countries signed onto the CRS and committed to begin sharing information in 2017. Other countries, including Canada, are committed to begin sharing information in 2018. Canada is not expected to begin drafting any specific implementing legislation or guidance before late 2015 at the earliest. The IIAC has been providing industry comments and feedback on the timing and implementation of the CRS to the Canadian Department of Finance and the Canada Revenue Agency (CRA), and will continue to do so.

Federal Immigrant Investor Program (IIP)

In response to a request from a number of members, the IIAC wrote to the Minister of Citizenship and Immigration Canada to recommend that the definition of the program “Facilitators” be expanded to include IIROC-registered investment dealers and request that the IIP application backlog be cleared expeditiously and fairly. The Minister acknowledged the letter.

T1135s

Starting last year, IIAC Member staff were approached by tax professionals seeking help in completing CRA T1135s – Foreign Income Verification Statement – for clients. While not a requirement for Member firms to report, the significantly more detailed information required by the new forms demanded that clients seek extensive help from Member firms to complete the form or risk increased penalties. The IIAC achieved a simplified solution for 2013 reporting for IIROC dealers, which the Taxation Reporting Committee estimates saved the industry several million dollars in potential costs to help clients meet the requirements.

The IIAC proposed permanent reporting amendments in March 2014 to help clients and dealers. A meeting with the Chartered Professional Accountants and the CRA was held June 10, 2014 when the CRA provided changes that differed from both the original, transitional and proposed approach. After Member firms assessed the changes, it appeared that they would be difficult to accommodate in 2014. The IIAC recommended the CRA make at least some changes or again adopt transitional rules given the late receipt of information. The IIAC and CPA Canada sent a joint letter to the Department of Finance to increase the T1135 reporting threshold, a measure that would reduce work by advisors and dealers. Once the CPA advised the CRA that 6,000 (now 7,000) individuals have signed up for a T1135 webinar to be held November 18, 2014, the CRA accepted to discuss what we hope will be FAQs that can provide some streamlining. The CPA and IIAC are also meeting with senior CRA officials

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on November 18 on technical and policy matters. The IIAC President will raise the matter in a meeting with Paul Rochon, Finance Deputy Minister, on November 19.

Operational Assistance – Best Practices and Tools

For details, please refer to the IIAC Website

Canadian Anti-Spam Legislation (CASL) Toolkit

Client Relationship Model (CRM) Member Support • CRM2 Toolkit (member-only website, Industry Impact, Key Issues, CRM) • What you should know about CRM – one-page summary of CRM1 and CRM2 • Model CRM2 performance benchmark stuffers • DOs and DON’Ts for investment advisors • Debt trade confirmation mock-up • Explaining difference between of time- and money-weighted rates of return • Using Fund Facts for mutual fund and point of sale disclosure (optional) • Template script for pre-trade disclosure (optional) • Using required deposit-type investment regulation disclosure for pre-trade

disclosure (optional) • Ways to encourage clients to bring client-name accounts on book • CRM2 Newsletter – CRM2 Countdown • Webinar: CRM2: What Advisors Need to Know – 1 CE credit • Webinar: CRM2: Cracking the Code – 1 CE credit • Webinar: ACB: Do Your Clients Pay Too Much Tax? (includes segment on challenges

of position cost) – eligible for .75 CE credit at firm discretion) • Pre-trade disclosure survey • Relationship disclosure benchmark wording • Annual compensation report prototype and data map • Annual performance report prototype and data map • CRM1 Toolkit • Enhanced suitability automation and standardization presentation • A conflict-of-interest “template” reflecting IIROC input • A conflict-of-interest self-assessment tool • An RD “considerations” document • Enhanced suitability roundtable

CRA Non-Resident Agreements

Referral Agreements and Disclosure Templates

Guidance on Compliance with CRTC Telemarketing Regulation (Do Not Call Rules)

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Guidance Notes Added to IIAC New Issue Practices Handbook (formerly Syndicate Practices Handbook)

IIAC Guidance Notice on the Québec Derivatives Act

Anti-Money Laundering (AML) Requirements

Marketplace Communications Protocol

Product Due Diligence

Non Brokered Private Placement Best Practices

Outside Business Activities Template

Fixed Income Central Counterparty and Netting Utility Model Securities Account Control Agreement

New York No-Action Letters

New Disclosure Requirements for Segregated Funds

Third Party Determination – Comfort Letter

Debt Syndication Practices

2013 Tax Reporting from Income Trusts and LPs

Publications

Securities Industry Savings-to-Investment Prosperity Cycle: Synopsis to help government, media and other audiences understand the role of the securities industry. Providing a snapshot of the securities industry, it highlights the members’ support for retail and institutional clients, and how the industry connects savers and investors to help generate economic activity and jobs.

Retail Publications

IIAC has issued a number of retail publications. The Retirement Planning Guide, Bonds: An introduction to bond investing, Bonds: More on bond investing, the IIROC Registered

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Advisor Advantage and the 5Ws of investing, Answering Your Questions are available on the Publications page of www.iiac.ca.

The ‘Security’ in the Securities Industry Brochure: An investor awareness piece that summarizes some of the major regulatory and structural elements unique to the Canadian securities industry which safeguard investors. The two-page piece touches on the roles of IIROC, CIPF, securities commissions and the clearing agencies.

Equity Capital Markets New Issue Practices (formerly Syndicate Practices Handbook): IIAC has published the New Issue Practices which will help firms in improving the efficiency of the underwriting process, especially in the execution of bought deals. It will also provide firms with a better understanding of their responsibilities in underwriting and selling newly issued securities to the public by providing a baseline reference point for syndicate managers to indicate possible differences from the normal practice.

*Debt Markets Syndication Best Practices: IIAC has published Debt Markets Syndication Best Practices which illustrates industry “best practices” in the syndication of corporate and provincial debt offerings. The document was prepared by a working group of industry professionals under the auspices of the IIAC and is available on the IIAC website.

Value of Advice: The IIAC has assembled results from a range of studies regarding the quantification of the value of advice on financial outcomes for Canadians. This can be useful for advisors or members’ communications or newsletter purposes.

*2015 CEO Survey: On January 8, 2015, the IIAC released the results of IIAC 2015 Capital Markets Outlook: A Survey of Canada's Investment Industry CEOs. The survey results show Canada’s investment industry CEOs are optimistic about the outlook for capital markets and their individual firms in the coming year.

Protecting Senior Investors Report: On March 18, 2014 the IIAC released a guidance report, entitled Canada’s Investment Industry: Protecting Senior Investors, to share best practices investment dealer firms and advisors are using when working with senior clients. The report underscores how seriously the industry takes its responsibility to ensure senior investors are being served in an ethical, respectful and informed manner. It also calls attention to the important role firms and advisors are playing in protecting this client base.

Industry Profile-Building Initiatives *Ian Russell addresses the Empire Club of Canada: On January 8, 2015, Ian Russell, IIAC President and CEO, unveiled the results of the third annual IIAC Capital Markets Outlook: A Survey of Canada’s Investment Industry CEOs in a speech at The Empire Club of Canada’s 2015 Outlook Luncheon. The survey results show Canada’s investment industry CEOs are

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optimistic about the outlook for capital markets and their individual firms in the coming year. Russell appeared on BNN following the speech to further discuss the 2015 outlook. *Ian Russell Letter to the Editor in the Financial Post: In recent weeks, there has been an onslaught of editorials and opinion pieces in the Financial Post harshly critical of draft legislation proposed for the cooperative securities regulator. Ian Russell penned a response to clarify the IIAC’s position and shape the conversation regarding the regulator entitled “Regulator’s flaws are fixable; the proposed securities regulator for Canada has major advantages, minor problems”, which the IIAC successfully placed in the December 29, 2014 issue of the Post. *IIAC Media Advocacy: The IIAC continues to leverage its strong media profile to shape the conversation around timely and relevant industry issues. Since the last Activity Update, the IIAC has appeared frequently in the media to (A) reiterate our call for the CSA to align certain 2015 and 2016 CRM2 implementation timelines with the beginning of the calendar year, and (B) to call on CRA to provide greater clarity around the behaviour that constitutes “carrying on a business” in a tax-free savings account. *IIAC Letter from the President Since the last IIAC Activity Update, Ian Russell, IIAC president and CEO, penned two Letters from the President focusing on issues of importance to the investment industry:

V80 – 2014 Year-End Review: A Resume of Developments and Trends in the Investment Industry over the Past Year

V79 – Trade Agreement With EU Offers Big Opportunities for Canada – and the Investment Industry

*IIAC in the News In Q4 2014, the IIAC was mentioned in 145 media stories, generating 40,575,561 total media impressions. 100% of coverage was positive or neutral in tone; 100% of articles featured the IIAC’s key messages. *Upcoming Seminars/Events

February 12, 2015: Webinar: Where in the world is your data? (IIAC members only) • April 1, 2015: Spring Compliance and Operations Symposium (Toronto)

March 25-26, 2015: Canadian Institute FATCA Compliance Conference: Andrea Taylor co-Chair and moderator (Toronto)

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