Last-mile CPH review: KYC/suitability workflow, conflicts, communications, complaints, AML, market integrity, supervision, plus a large compliance terminology glossary and light formulas.
Use this as your “what do I do next?” playbook for CPH scenarios. Pair it with the Syllabus for coverage and Practice for speed and judgment.
flowchart TD
A["Scenario"] --> B["Get facts (KYC/KYP)"]
B --> C["Suitability + fair dealing"]
C --> D{"Conflict / Complaint / AML / MNPI?"}
D -->|Yes| E["Escalate + disclose + follow policy"]
D -->|No| F["Proceed with compliant action"]
E --> G["Document + retain records"]
F --> G
G --> H["Monitor / supervise"]
| Item | Official value |
|---|---|
| Exam format | Proctored (remote or in-person at a test centre) |
| Question format | Multiple Choice |
| Questions per exam | 100 |
| Exam duration | 3 hours |
| Passing grade | 60% |
| Attempts allowed per exam | 3 |
| Exam topic | Weighting |
|---|---|
| Standards of Conduct and Ethics, Ethical Decision Making, and Putting it All Together | 23% |
| The Canadian Regulatory Framework | 12% |
| Working with Clients | 13% |
| Client Discovery and Account Opening | 13% |
| Product Due Diligence, Recommendations, and Advice | 13% |
| Trading, Settlement, and Prohibited Activities | 13% |
| Maintaining Client Accounts and Relationships | 13% |
These chapter titles and subtopics are from CSI’s CPH Curriculum page.
| You see this in the stem… | It’s probably testing… | The safest high-scoring move |
|---|---|---|
| “Client profile changed” | KYC update + suitability refresh | update KYC, reassess, document before recommending |
| “Referral fee / gift / outside job” | conflict of interest | disclose, get pre-approval, record it |
| “Guarantee / promise / ‘risk-free’” | misleading communications | correct the statement; disclose risk; avoid guarantees |
| “Client is angry / alleges loss” | complaint handling | acknowledge, document, escalate, follow process |
| “Unusual funds / reluctant to ID” | AML + monitoring | escalate to AML officer; document; don’t tip off |
| “Friend at issuer / takeover rumour” | MNPI / insider risk | stop trading guidance; escalate; restrict access/trading |
| “Trade error / wrong account” | error correction | report immediately; correct per policy; document |
| “Discretionary trading?” | authority + supervision | only with required agreement/approval; document |
Write notes like a regulator will read them:
When the question asks “what should the representative do?”, KYP is often the hidden answer.
| KYP item | What to check | Typical exam cue |
|---|---|---|
| Risk | market, credit, liquidity, leverage, concentration | “high yield”, “structured”, “private”, “derivative” |
| Costs | commissions, trailers, spreads, management fees | “fee-sensitive”, “compare products” |
| Complexity | can the client understand it? | “new investor”, “limited knowledge” |
| Liquidity | lockups, gates, redemption terms | “needs access to cash”, “short horizon” |
| Suitability fit | who it’s for / not for | “low risk tolerance” + “high-risk product” |
| Situation | Why it’s a conflict | Best exam response |
|---|---|---|
| Referral fees / third-party compensation | incentive to recommend | disclose in plain language; get approval; document |
| Gifts / entertainment | could influence judgment | follow limits; pre-approve when needed; record it |
| Outside business activities (OBA) | divided loyalties + supervision risk | disclose to firm; get pre-approval; ongoing monitoring |
| Personal trading / related accounts | competing with clients | follow personal trading policy; avoid front-running; record |
| Related/connected issuer relationships | issuer influence | enhanced disclosure; higher supervision; avoid biased comms |
| Sales contests / quotas | incentive distortion | avoid product-first behaviour; treat fairly; document suitability |
| Communication element | Usually OK | Usually risky |
|---|---|---|
| Performance | explain methodology + context | cherry-picking, “always beats market” |
| Projections | clearly labeled assumptions and limits | “will earn 10%”, “guaranteed income” |
| Comparisons | comparable benchmarks and timeframes | misleading apples-to-oranges comparisons |
| Social media | pre-approved educational posts | testimonials, exaggerated claims, unapproved promotions |
| Order | What it does | Main risk |
|---|---|---|
| Market | executes at best available | price uncertainty in fast markets |
| Limit | price control | may not fill |
| Stop | triggers when price level hit | gaps/slippage after trigger |
| Stop-limit | triggers then becomes limit | may not fill after trigger |
| Step | Do | Don’t |
|---|---|---|
| Intake | record facts and timelines | argue or blame the client |
| Investigation | gather records, notes, communications | delete messages / “clean up” files |
| Response | follow approved wording, be factual | promise outcomes you can’t control |
| Resolution | implement corrective actions; learn | retaliate or discourage complaints |
| Pattern | What it looks like | Better answer framing |
|---|---|---|
| Insider trading / tipping | trading on non-public deal info | stop + escalate + restrict |
| Front-running | trading ahead of client/firm order | client-first + policy + records |
| Churning | excessive trades for commissions | suitability + client objective + supervision |
| Unauthorized trading | trades without consent/authority | escalate + remediation + documentation |
| Manipulation | wash trades / spoofing / false liquidity | market integrity + escalation |
Total return \[ TR=\frac{V_1-V_0+I}{V_0} \]
What it tells you: Total return over a period = change in value plus income, relative to the starting value.
Symbols (what they mean):
How it’s tested (CPH style):
Common pitfalls:
Annualized return (if you need it) \[ R_{\text{ann}}=(1+TR)^{1/n}-1 \]
What it tells you: The constant annual compound rate that would produce the same total return over \(n\) years.
Symbols (what they mean):
How it’s tested:
Common pitfalls:
Real return (approx) \[ R_{\text{real}}\approx R_{\text{nominal}}-\pi \]
What it tells you: The approximate return after inflation (purchasing-power return).
Symbols (what they mean):
Exam note: This is an approximation; the exact relationship is \(1+r_{real}=\frac{1+r_{nom}}{1+\pi}\).
Markup / markdown (percent) \[ %\text{Markup}=\frac{\text{Sell price}-\text{Cost}}{\text{Cost}} \] \[ %\text{Markdown}=\frac{\text{Cost}-\text{Buy price}}{\text{Cost}} \]
What it tells you: The dealer’s compensation (as a percent of dealer cost) when selling to or buying from a client.
Symbols (what they mean):
How it’s tested:
Common pitfalls:
Current yield (bond) \[ CY=\frac{\text{Annual coupon}}{\text{Market price}} \]
What it tells you: A bond’s income yield today (coupon income divided by current price), ignoring capital gains/losses.
What it is NOT: Current yield is not YTM; it does not capture price pull-to-par or reinvestment assumptions.
How it’s tested:
Accredited investor — Investor meeting specific criteria that may allow access to certain products (policy-driven suitability considerations still apply).
Acknowledgement — Confirming receipt/understanding of a disclosure or document (often part of recordkeeping).
Advertising — Promotional communications subject to firm approval and record retention.
AML/ATF — Anti-money laundering / anti-terrorist financing program duties (monitoring, escalation, reporting via policy).
Approved person / registrant — Individual registered to perform regulated activities under firm supervision.
Assignment — (Options) Writer obligation triggered when holder exercises; relevant when discussing leveraged/high-risk products.
Authority to trade — The legal/contractual permission to place trades (client, POA, managed account agreement).
Beneficial owner — Natural person(s) who ultimately own/control an entity; key AML concept.
Best execution — Duty to seek the best overall terms reasonably available, consistent with policy and market conditions.
Branch supervision — Oversight controls (pre-trade/post-trade reviews, approvals, monitoring) to ensure compliant activity.
Capital preservation — Objective emphasizing low loss probability, often implying lower volatility/liquidity risk.
Churning — Excessive trading primarily to generate commissions, inconsistent with client interests.
Client-first / fair dealing — Principle that client interests and fair outcomes matter in recommendations and disclosures.
Complaint — Expression of dissatisfaction about products/services/representations requiring intake, documentation, and escalation.
Compliance — Framework of policies, monitoring, and controls that enforce rules and ethical standards.
Conflict of interest — Situation where personal/firm incentives could impair objectivity; requires mitigation/disclosure.
Connected issuer — Issuer with a meaningful relationship to the dealer/firm (heightened conflict/disclosure considerations).
Concentration risk — Overexposure to one security/sector/issuer causing disproportionate loss potential.
Consent — Client agreement/authorization; in exam answers, “informed consent + documentation” matters.
Discretionary trading — Trading without prior client approval for each order; requires strict agreements/approvals.
Disclosure — Clear communication of risks, costs, conflicts, and limitations, provided in time for the client to act.
Documentation — Written records supporting KYC, suitability, disclosures, client instructions, and outcomes.
Dual employment / OBA — Outside business activity requiring firm disclosure and supervision controls.
Escalation — Bringing an issue to supervision/compliance per policy (complaints, AML, conflicts, MNPI, errors).
Exempt product — Product with different distribution rules; suitability and KYC still apply.
Fair presentation — Communications that do not mislead by omission or selective emphasis.
Front-running — Trading ahead of a client/firm order to benefit from expected price movement.
Gifts and entertainment — Items of value that can create conflicts; subject to limits, approval, and recordkeeping.
Identity verification — Confirming who the client is; foundational AML requirement.
Inside information / MNPI — Material non-public information; do not trade or advise based on it; escalate.
KYC (Know Your Client) — Client profile used for suitability: objectives, risk, horizon, liquidity, constraints, identity.
KYP (Know Your Product) — Understanding product features, risks, costs, liquidity, and suitability fit.
Limit order — Order to trade at a specified price or better; controls price but risks non-execution.
Liquidity — Ability to access cash quickly without large price concessions or penalties.
Maintenance margin — Minimum margin level before a margin call; leverage risk concept.
Managed account — Account where an authorized portfolio manager makes discretionary decisions under mandate.
Market manipulation — Conduct intended to mislead market participants (false liquidity, artificial prices).
Market order — Order to execute immediately at best available price; price uncertainty trade-off.
Market integrity — Maintaining fair and orderly markets; avoiding manipulative or deceptive practices.
Misrepresentation — False or misleading statements/omissions; communications must be accurate and balanced.
Monitoring — Ongoing review of suitability and account activity; update KYC as needed.
Outside business activity (OBA) — Non-firm business or employment; requires disclosure, approvals, monitoring.
Personal trading policy — Firm rules governing employee trading to prevent conflicts and front-running.
Power of attorney (POA) — Legal authority to act for a client; must be verified and recorded.
Product suitability — Fit of the product to client needs and constraints; part of overall suitability.
Prohibited conduct — Activities disallowed by regulation/policy (insider trading, manipulation, unauthorized trades).
Recommendation — Advice to act; triggers suitability expectations and documentation requirements.
Record retention — Keeping required records for required timeframes; governed by regulation and firm policy.
Referral arrangement — Compensation for referring clients; requires disclosure and oversight.
Restricted list — List of securities with trading/solicitation restrictions due to MNPI/conflict concerns.
Risk capacity — Financial ability to bear losses (cash flow, horizon, net worth).
Risk tolerance — Emotional willingness to experience volatility and loss.
Sales practice — How recommendations and communications are conducted; must be ethical and compliant.
Sanctions — Restrictions on dealing with certain persons/entities/jurisdictions; escalated via compliance.
Source of funds — Where the money comes from; important AML and suitability context.
Stop order — Trigger-based order; execution price can vary after trigger due to gaps.
Suitability — Matching recommendations to the client’s profile and constraints, with documentation.
Supervision — Oversight ensuring activities are compliant and appropriately controlled.
Trade error — Incorrect trade or allocation; must be escalated and corrected transparently.
Trailer fee — Ongoing compensation embedded in some fund series; conflict/cost disclosure relevance.
Unauthorized trading — Trading without client consent/authority; major compliance breach requiring escalation.
Watch list — Monitoring list for heightened review (often prior to restricted list); compliance tool.
Always defer to your firm’s policies and current CSI/CIRO guidance for exact procedures and definitions; the exam typically rewards the safest compliant action with clear documentation.
Sources: https://www.csi.ca/en/learning/courses/cph/curriculum and https://www.csi.ca/en/learning/courses/cph/exam-credits