Policy Statement to Regulation 33-109 Respecting Registration Information

Policy Statement to Regulation 33-109 June 6, 2022 1 LAST AMENDMENTS IN FORCE ON JUNE 6, 2022 POLICY STATEMENT TO REGULATION 33-109 RESPECTING REGISTRATION INFORMATION PART 1 GENERAL 1.1. Purpose This Policy Statement sets out how the Canadian Securities Administrators interpret or apply Regulation 33-109 respecting Registration Information (chapter V-1.1, r. 12) (the Regulation). The registration requirement in securities legislation provides protection to investors from unfair, improper or fraudulent practices and enhances capital market integrity and efficiency. The information required under the Regulation allows regulators to assess a filer’s fitness for registration or for permitted individual status, with regard to their solvency, integrity and proficiency. These fitness requirements are the cornerstones of the registration requirement. In each jurisdiction of Canada the registration requirement and the Regulation apply to dealers, underwriters, advisers and investment fund managers and to individuals who act on their behalf as registered or permitted individuals. 1.2. Definition of permitted individuals (Section 1.1) Section 1.1 of the Regulation defines a permitted individual as an individual who meets the criteria set forth in paragraph (a), (b) or (c) of the definition. A permitted individual may or may not be a registered individual. For example, the chief executive officer of a registered firm is registered as the firm’s ultimate designated person and is also a permitted individual. The definition of permitted individual allows the Regulation to separate out the filing requirements which are applicable only to permitted individuals from those which are applicable to registered individuals. 1.3. Overview of the forms The following forms are for firms: • Form 33-109F3 Business Locations other than Head Office – to disclose each business location of the firm and any change of business location • Form 33-109F6 Firm Registration – to apply for registration as a dealer, adviser or investment fund manager The following forms are for individuals and are submitted in NRD format:

Policy Statement to Regulation 33-109 June 6, 2022 2 • Form 33-109F1 Notice of End of Individual Registration or Permitted Individual Status – to notify the regulator or, in Québec, the securities regulatory authority that a registered individual or permitted individual has ceased to have authority to act on behalf of the sponsoring firm; • Form 33-109F2 Change or Surrender of Individual Categories – to apply for registration or review in an additional category or to surrender a category • Form 33-109F4 Registration of Individuals and Review of Permitted Individuals – to apply for registration or review as a permitted individual • Form 33-109F7 Reinstatement of Registered Individuals and Permitted Individuals – to reinstate an individual’s registration or a permitted individual status 1.4. Notice requirements (Sections 3.1 and 4.1) Form 33-109F5 Change of Registration Information is used by firms and individuals to notify regulators of any change to their registration information. Under sections 3.1 and 4.1 of the Regulation a registrant and a permitted individual must keep their registration information current on an ongoing basis by filing notices of change of information within the required time. Appendix A summarizes the notice requirements, time periods and the forms under the Regulation to notify regulators of a change to a firm’s or individual’s registration information. 1.5. Contact information When a firm submits a Form 33-109F6, supporting documents or a Form 33-109F5, it can make the submission using e-mail, fax or mail. Appendix B attached to this policy sets out the contact information for the regulator in each jurisdiction of Canada and for the Investment Industry Regulatory Organization of Canada (IIROC) in those jurisdictions where the securities regulatory authority has delegated, assigned or authorized IIROC to perform registration functions. PART 2 FORMS USED BY INDIVIDUALS 2.1. National Registration Database (NRD) The NRD is the database containing information about all registrants and permitted individuals under securities or commodity futures legislation in each jurisdiction of Canada. The requirement for firms to enrol, and to make certain submissions, on NRD are set out in Regulation 31-102 respecting National Registration Database (chapter V-1.1, r. 9). Detailed information about the NRD and the enrolment process is available in the NRD User Guide published at www.nrd-info.ca.

Policy Statement to Regulation 33-109 June 6, 2022 3 2.2. Form 33-109F4 Types of submissions using Form 33-109F4 (Subsections 2.2(1) and 2.5(1)) The NRD format for submitting a completed Form 33-109F4 under subsection 2.2(1) or 2.5(1) of the Regulation include 4 distinct NRD submission types that are made in the following circumstances: • Initial Registration, when an individual is seeking registration, or review as a permitted individual, through NRD for the first time • Registration in an Additional Jurisdiction, when an individual is registered or is a permitted individual in a jurisdiction of Canada and is seeking registration, or review as a permitted individual, in an additional jurisdiction; • Registration with an Additional Sponsoring Firm, when an individual is registered, or is a permitted individual, on behalf of one sponsoring firm and applies for registration, or seeks review as a permitted individual, to act on behalf of an additional sponsoring firm • Reactivation of Registration, when an individual who has an NRD record is applying for registration, reinstatement of registration or is seeking review as a permitted individual and is not eligible under subsection 2.3(2) or 2.5(2) of the Regulation to submit a Form 33-109F7 Submissions by permitted individuals (Sections 2.3 and 2.5) Under subsection 2.5(1) of the Regulation, within 15 days of becoming a permitted individual, the individual must submit a Form 33-109F4 for review by the regulator. An individual whose registration is suspended may apply to reinstate the registration by submitting a completed Form 33-109F4 to the regulator. This is done with the Reactivation of Registration submission on NRD. After making this submission the individual may not conduct activities requiring registration unless and until the regulator has approved the application. However, an application for reinstatement or review is not required if the individual meets all of the conditions for automatic reinstatement in subsection 2.3(2) or 2.5(2) of the Regulation, which include submitting a completed Form 33-109F7 to the regulator as described in section 2.5 below. Relevant securities experience (Form 33-109F2 – Item 4.3 and Schedule A; Form 33-109F4 – Item 8.4 and Schedule F) The regulators or, in Québec, the securities regulatory authority will assess whether an individual has gained relevant securities experience on a case-by-case basis. It may include experience acquired: • during employment at a registered dealer, a registered adviser or an investment fund manager;

Policy Statement to Regulation 33-109 June 6, 2022 4 • in related investment fields, such as investment banking, securities trading on behalf of a financial institution, securities research, portfolio management, investment advisory services or supervision of those activities; • in legal, accounting or consulting practices related to the securities industry; and • in other professional service fields that relate to the securities industry, or in a securities-related business in a foreign jurisdiction. The securities experience described should be relevant to the category applied for. Please see section 3.4 of Policy Statement to Regulation 31-103 respecting Registration Requirements, Exemptions and Ongoing Registrant Obligations (Decision 2011-PDG-0074, 2011-06-07) for more guidance on relevant securities experience. Reportable activities (Form 33-109F4 – Item 10 and Schedule G; Form 33-109F7 – Item 7 and Schedule D) Individuals must report all activities with their sponsoring firm and certain activities carried on outside of their sponsoring firm (which includes activities performed for affiliated entities of their sponsoring firm) in Form 33-109F4 and Form 33-109F7. Activity changes must be reported by the individuals in Form 33-109F5. To illustrate the analysis on whether an activity outside of the sponsoring firm is reportable in Item 10.2 of Form 33-109F4 or in Item 7.2 of Form 33-109F7, Appendix C has been included in this Policy Statement. The regulator or, in Québec, the securities regulatory authority will take into account reportable activities when assessing that individual’s application for registration or continuing fitness for registration and the sponsoring firm’s fitness for registration, including the following considerations in relation to the reportable activities: • whether there is a risk of client confusion and if so, what the risk is and whether there are effective controls and supervision in place to address the risk, • whether the reportable outside activity presents a material conflict of interest for the individual, and whether that material conflict of interest has been addressed in the best interest of the client, • whether the reportable outside activity provides the individual with access to privileged, confidential or insider information relevant to their registerable activities, • whether the individual will have sufficient time to effectively carry out their registerable activities, including remaining current on securities law and product knowledge, • whether the individual will be able to properly service clients.

Policy Statement to Regulation 33-109 June 6, 2022 5 Information on outside activities reported to the regulators or, in Québec, the securities regulatory authority also helps facilitate their understanding and supervision of registrants and, in some circumstances, may prompt further review of an applicant, a registrant, a permitted individual, or an unregistered person. Although only certain outside activities are required to be reported to regulators or, in Québec, the securities regulatory authority, registrants are required to identify and address all material conflicts of interest and risks associated with their sponsored individuals, including those arising from outside activities that a registered individual may participate in. Accordingly, the assessment of material conflicts of interests by registrants should not be limited to only the outside activities reportable to regulators or, in Québec, the securities regulatory authority. Category 1 – Activities with another registered firm Generally, we expect any activity with another registered firm to be reported, whether or not the activity at the other firm requires the individual to be registered. For example, the following roles are reportable: being an advising or dealing representative, owner, director, research analyst, compliance consultant, client relationship manager, human resources manager, or IT service provider for another registered firm. Category 2 – Activities with an entity that receives compensation from a registered firm If the individual is the owner (e.g., shareholder, partner), management (e.g., director or officer), or employee of an unregistered entity that receives compensation, such as sales commissions or referral fees, from a registered firm, this activity is reportable. For example, being an employee or owner of an entity that has entered into an agreement in the form set out in Schedule ‘A’ of MFDA Staff Notice MSN-0072 Payment of Commissions to Unregistered Corporations is reportable. Category 3 – Other securities-related activities Activities that involve raising money for an entity, such as structuring the security or derivative, preparing the offering document, soliciting investors, or promoting the sale of a security or derivative are reportable. The activity must be reported if it was carried out any time in the last 7 years. Given the role of a director or officer in a corporation as the directing mind and management and the nature of partnerships and trusts, we would consider a director, officer, partner, or equivalent position (such as trustees) of an entity that, within the last 7 years, raised money through the issuance of securities or derivatives to be directly involved and thus would be reportable. For example, being the President of a mortgage investment entity that is raising money would be reportable. We would also consider being a director or officer of a reporting issuer to be reportable, such as being a director of a TSX-listed company. An individual who works at an entity that is raising money through the issuance of securities or derivatives, but has no direct involvement in the capital raising activity,

Policy Statement to Regulation 33-109 June 6, 2022 6 such as a computer programmer at a fintech start-up, would not be required to report, unless the activity falls within another reporting category. Similarly, charitable or other fundraising activities that do not involve the issuance of securities or derivatives would not be reportable. For example, volunteering for an organization to seek charitable donations would not be reportable. Category 4 – Provision of financial or finance-related services An individual is required to report certain financial and finance-related activities, whether or not compensation is received for providing the services. An individual is also expected to report if the individual is a shareholder, partner, director, or officer of an entity that provides one of those services. This includes activities where the individual is responsible for the oversight or provides independent review or expert opinion on the management of an entity’s financial assets. For example, being a member of an investment committee that oversees the management of a university’s endowment funds or a charity’s financial capital, or being a trustee of a family trust. Category 5 – Positions of influence A position of influence is defined in section 13.4.3 of Regulation 31-103 respecting Registration Requirements, Exemptions and Ongoing Registrant Obligations (chapter V-1.1, r. 10). All positions of influence are reportable. Please see the guidance in section 13.4.3 of Policy Statement to Regulation 31-103 respecting Registration Requirements, Exemptions and Ongoing Registrant Obligations. Uncompensated activities and personal holding companies Generally, uncompensated activities that do not involve securities or financial services and are not positions of influence are not reportable. For example, volunteer activities, such as being a little league soccer coach or volunteering at an animal shelter, are not required to be reported as they do not fall within Categories 1 to 5. Additionally, involvement with entities with non-active operations, such as being the owner of a holding company (e.g., passive management of personal investments), would likely not be reportable. However, in some cases personal holding companies are used to hold securities of a registered firm and through this arrangement the individual receives indirect compensation from a registered firm. In this case the involvement with the holding company would be reportable under Category 2. In other circumstances the holding company is used to provide financial or finance-related services, to provide services for registered firms, or is otherwise involved in securities-related activities. If an individual’s holding company is used for activities that would require disclosure under any of Categories 1 to 5, we would generally consider this entity to be active and the individual should disclose the individual’s involvement with this entity.

Policy Statement to Regulation 33-109 June 6, 2022 7 Resignation and terminations (Form 33-109F4 – Item 12 and Schedule I) Individuals must report whether they have resigned or been terminated from a position or contract and whether, at the time of their resignation or termination, there existed allegations that the individual: (i) contravened any statutes, regulations, orders of a court or regulatory body, rules or bylaws, or failed to meet standards of conduct, (ii) failed to appropriately supervise compliance with any statutes, regulations, orders of a court or regulatory body, rules, bylaws or standards of conduct, or (iii) committed fraud or the wrongful taking of property, including theft. Standards of conduct may be internal to the sponsoring firm, such as a sponsoring firm’s policies and procedures, or may be external to the sponsoring firm, such as the standards of conduct of a professional body. Standards of conduct may include codes of conduct. Sales targets of the firm are not considered standards of conducts. When providing information about resignations or terminations, individuals must disclose the day that they ceased to carry on duties for the entity or firm they resigned or were terminated from. This date may coincide with the end of the individual’s employment, partnership or agency relationship. However, this date can also occur earlier, such as when an individual is subjected to an internal firm suspension or the individual’s authority has otherwise been reduced or curtailed pending an internal review. Individuals should provide the date they ceased to carry on duties and not merely the end of an individual’s employment, partnership or agency relationship. Agent for service (Form 33109A4 – Item 18) Item 18 Agent for service of Form 33-109F4 is a certification clause by the individual that he or she has completed the appointment for service required in each relevant jurisdiction. There is no distinct form under Regulation for the appointment of an agent for service for use by individuals. Please refer to the form used by the registered firm. This format is acceptable to the regulator. 2.3 Form 33-109F2 (Subsection 2.2(2), Section 2.4, Subsection 2.6(2), Subsection 4.1(4)) This form is used by individuals to apply to add or to surrender a registration category, to seek review of a change in their permitted individual category or to change any information on Schedule C of a previously submitted Form 33-109F4. If an individual has ceased to have authority to act on behalf of their sponsoring firm as a registered or permitted individual in the last jurisdiction of Canada where they were so acting, they cannot submit a Form 33-109F2. Instead, the individual’s sponsoring firm submits a Form 33-109F1 to notify the regulator of the termination or cessation of authority to act on behalf of the firm. 2.4 Form 33-109F5 for individuals When an individual submits a Form 33-109F5 to update their registration information, NRD will transmit the information to the regulator in each jurisdiction in which the individual is registered or is a permitted individual. However, only the principal

Policy Statement to Regulation 33-109 June 6, 2022 8 regulator processes the submission to update the individual’s registration information on NRD, or if necessary to deny or withdraw the submission. Form 33-109F5 should not be used by an individual applying to add or surrender a registration category or to seek review of a change in his/her permitted individual category. In this case, Form 33-109F2 is used. It should also be noted that Form 33-109F5 is not used by an individual that is registered or is a permitted individual in a jurisdiction of Canada and is seeking registration, or review as a permitted individual, in an additional jurisdiction. In this case, a Form 33-109F4 is used and is identified on NRD as Registration in an Additional Jurisdiction. This also applies to an individual adding a sponsoring firm; Form 33-109F4 is used and is identified on NRD as Registration with an Additional Sponsoring Firm. 2.5 Form 33-109F7 for reinstatement (Sections 2.3 an 2.5) When an individual leaves a sponsoring firm and joins a new registered firm, they may submit a Form 33-109F7 to have their registration or permitted individual status automatically reinstated in one or more of the same categories and jurisdictions as before, subject to all of the conditions set out in subsection 2.3(2) or 2.5(2) of the Regulation. An individual who meets all of the applicable conditions will be able to transfer directly from one sponsoring firm to another and start engaging in activities requiring registration from the first day that they submit the Form 33-109F7. If certain allegations existed at the time of the individual leaving a sponsoring firm, then regardless of whether the allegations caused or contributed to the individual leaving, the individual may not use the Form 33-109F7. In addition, at the time the individual ceased to be a registered individual or a permitted individual with the former sponsoring firm, all of the information previously submitted in Form 33-109F4, including Item 12, must have been up to date. If these conditions are not met, then the individual must apply for reinstatement by completing on NRD a Form 33-109F4 by making the NRD submission entitled “Reactivation of Registration 2.6. Business locations (Form 33-109F4 and Form 33-109F7) The term “business location” is defined in section 1.1 of the Regulation. If the business location specified in Item 9 of Form 33-109F4 or Item 5 of Form 33-109F7 is a residence, the individual must acknowledge that the regulator or, in Québec, the securities regulatory authority may request consent to enter the residence for the administration of securities legislation and derivatives legislation, including commodity futures legislation. 2.7. Ongoing fitness for registration Every registrant must maintain their fitness for registration on an ongoing basis. Under securities legislation, the regulator has discretionary authority to suspend or revoke an individual’s registration or to restrict it with terms and conditions at any time. The regulator may do this, for example, if it receives information through a notice of cessation from an individual’s former sponsoring firm or any other source that raises

Policy Statement to Regulation 33-109 June 6, 2022 9 concerns about the individual’s continued fitness for registration. Individuals will be given an opportunity to be heard before a decision is made to suspend or revoke registration or to impose terms and conditions. PART 3 FORMS USED BY FIRMS 3.1. Form 33-109F6 (Paragraph 2.1(a)) When a firm submits a Form 33-109F6 to apply for registration, it may pay the regulatory fees to the applicable regulators by cheque or by using the NRD function called Resubmit Fee Payment. A firm that applies in multiple jurisdictions should submit its application to the regulator in the principal jurisdiction or, if Ontario is a non-principal jurisdiction, to the regulators in the principal jurisdiction and in Ontario. For more details refer to Policy Statement 11-204 respecting Process for Registration in Multiple Jurisdictions (Decision 2009-PDG-0115, 2009-09-04). Under section 4A.1 of Regulation 11-102 respecting Passport System (chapter V-1.1, r. 1), the principal regulator for a foreign firm is the securities regulatory authority or regulator identified in Item 2.2(b) of the firm’s most recent Form 33-109F6 or Form 33-109F5 – Change of Registration Information if the change noted in that form relates to Item 2.2(b) of Form 33-109F6. For firms without a head office in Canada or not already registered in a jurisdiction of Canada, Item 2.2(b) of Form 33-109F6 specifies that the principal regulator is the jurisdiction of Canada in which the firm expects to conduct most of its activities that require registration as at the end of its current financial year or conducted most of its activities that require registration as at the end of its most recently completed financial year. Firms should determine whether to base the selection on where they expect to conduct most of their activities or where they conducted most of their activities the previous year based on which they feel is most appropriate. The factors a firm should consider in identifying the principal regulator are: • the jurisdiction in which the firm has a business location, • when applying for dealer registration or adviser registration, the jurisdiction in which the firm expects to have most of its clients as at the end of its current financial year or the jurisdiction in which most of the firm’s clients were located at the end of its most recently completed financial year, • when applying for investment fund manager registration, the jurisdiction in which the firm expects to conduct most of its investment fund manager activities as at the end of its current financial year or the jurisdiction in which most of the firm’s investment fund manager activities were conducted at the end of its most recently completed financial year, • when applying for investment fund manager registration and another category of registration, the jurisdiction in which the firm expects to conduct most of the

Policy Statement to Regulation 33-109 June 6, 2022 10 activities that require registration as at the end of its current financial year or conducted most of the activities that require registration as at the end of its most recently completed financial year based on the foregoing. Under section 4A.2 of Regulation 11-102 respecting Passport System, a securities regulatory authority or regulator has the discretion to change the principal regulator for the firm. Changes in outstanding legal actions Registered firms are required to provide updates on the changes in legal actions reported in item 8.3 of Form 33-109F6. This includes new claims, defenses, counterclaims, third-party claims, amendments, settlements or resolutions of the claims (whether by judgement, dismissal or discontinuance), and appeals. In addition, we expect registered firms to inform regulators or, in Québec, the securities regulatory authority of any decisions in the legal action that could significantly adversely affect the firm’s financial health or business or affect the outcome of the legal action. Reporting of discovery, procedural and scheduling developments, such as adjournments, is not required. 3.2. Form 33-109F5 (Subsection 3.1(6)) A firm that is registered in multiple jurisdictions may submit a Form 33-109F5 to its principal regulator only to notify regulators of a change to the firm’s registration information, in accordance with subsection 3.1(6) of the Regulation. 3.3. Form 33-109F3 (Paragraph 2.1(b); Form 33-109F4 – Item 22) A firm must notify the regulator of each business location in the jurisdiction. The term “business location” is defined in section 1.1 of the Regulation and may include a residence where a firm’s registered individuals are based for the purpose of carrying out activities that require registration. Firms certify in Form 33-109F4 that if the business location is a residence, the individual conducting business from that business location has completed a Form 33-109F4. Form 33-109F4 contains a notice to the individual completing the form that the regulator or, in Québec, the securities regulatory authority may request consent to enter the residence for the administration of securities legislation. Firms submit this form through the NRD website. 3.4. Discretionary exemption for bulk transfers Regulators will consider an application for an exemption from certain requirements in the Regulation to facilitate a reorganization or combination of firms which would otherwise require a large number of submissions to change business locations and transfer individuals. The information required, and the conditions to obtain, this type of exemption application are described in the attached Appendix D.

Policy Statement to Regulation 33-109 June 6, 2022 11 3.5. Form 33-109F1 (Section 4.2) Under section 4.2 of the Regulation, a registered firm must notify the regulator or, in Québec, the securities regulatory authority no more than 15 days after an individual ceased to have authority to act on behalf of the registered firm, as a registered individual or permitted individual. Typically, this occurs due to the cessation of the individual’s employment, partnership or agency relationship with the registered firm. However, it also occurs when an individual is re-assigned to a different position at the registered firm that does not require registration or is no longer a permitted individual category. Section 4.2 requires that firms notify the regulator or, in Québec, the securities regulatory authority within 15 days of the date that the person ceased to have authority to act and not merely the end of an individual’s employment, partnership or agency relationship. Please refer to the definition “cessation date”. Form 33-109F1 is submitted through the NRD website to give notice of the cessation date and the reason for the cessation. Under paragraph 4.2(1)(b) of the Regulation, the information in Item 5 of a Form 33-109F1 must be submitted unless the cessation of authority to act on behalf of the registered firm was caused by the death of the individual. A registered firm can submit the information in Item 5 either at the time of making the initial submission on NRD, if the information is available within that 15 day period, or within 30 days of the cessation date, by making an NRD submission entitled “Update / Correct Cessation Information”. PART 4 DUE DILIGENCE BY FIRMS 4.1. Obligations of former sponsoring firm (Subsections 4.2(3) and (4)) After submitting a Form 33-109F1 with regard to a former sponsored individual a firm should promptly send the individual a copy of the completed Form 33-109F1. Under subsections 4.2(3) and (4) of the Regulation, within 15 days of a request by a former sponsored individual, a firm must provide the individual with a copy of the Form 33-109F1 that was submitted, and if necessary, a further copy that includes the information in Item 5 of the Form 33-109F1, within 15 days of submitting that information. 4.2. Obligations of new sponsoring firm (Section 5.1) In fulfilling its obligations under subsection 5.1(1) of the Regulation, a sponsoring firm should make reasonable efforts to do all of the following: • establish written policies and procedures to verify an individual’s information prior to submitting a Form 33-109F4 or Form 33-109F7 on behalf of the individual • document the sponsoring firm’s review of an individual’s information in accordance with the firm’s policies and procedures

Policy Statement to Regulation 33-109 June 6, 2022 12 • regularly remind registered and permitted individuals about their disclosure obligations under the Regulation, such as notifying the regulator about changes to their registration information Under subsection 5.1(2) of the Regulation, within 60 days of hiring a sponsored individual a sponsoring firm must obtain a copy of the most recent Form 33-109F1, if any, for the individual. If a sponsoring firm cannot obtain it from the sponsored individual, as a last resort the sponsored individual should request it from the regulator or, in Québec, the securities regulatory authority. The information referred to above will assist the sponsoring firm in meeting its obligations under subsection 5.1(1) of the Regulation and should inform the sponsoring firm’s hiring decisions. If an individual is hired before a completed Form 33-109F1 is available and if the sponsoring firm discovers an inconsistency in the individual’s disclosure to the firm or the regulator, then the sponsoring firm should take appropriate action. All of the required information should be available within 60 days of hiring the individual, which will often fall within the individual’s probation period under their employment or agency contract. PART 5 COMMODITY FUTURES ACT SUBMISSIONS 5.1. Ontario In Ontario, if a person is required to make a submission under both the Regulation and OSC Rule 33-506 (Commodity Futures Act) Registration Information with respect to the same information, the securities regulatory authority is of the view that a single filing on a form required under either rule satisfies both requirements. 5.2. Manitoba In Manitoba, the Regulation is a rule under each of the Securities Act (C.C.S.M. c. S50) and the Commodity Futures Act (C.C.S.M. c. C152). A single submission with respect to the same information will satisfy the requirements of both statutes.

Policy Statement to Regulation 33-109 June 6, 2022 13 Appendix A Summary of Notice Requirements in Regulation 33-109 Description of Change Notice Period Section Form Submitted Firms – Form 33-109F6 information by e-mail, fax or mail Part 1 – Registration details 15 days 3.1(1.1)(b) Form 33-109F5 Part 2 – Contact information, including head office address (except 2.4) 15 days Item 2.4 –Agent and Address for service [Items 3 and 4 of Schedule B to Form 33-109F6] 15 days 3.1(4) Schedule B to Form 33- 109F6 Submission to jurisdiction Part 3 – Business history & structure 30 days 3.1(1.1)(a) Form 33-109F5 Part 4 – Registration history (except item 4.1) 15 days 3.1(1.1)(b) Item 4.1 – Securities registration 30 days 3.1(1.1)(a) Part 5 –Financial condition (except item 5.12) 15 days 3.1(1.1)(b) Item 5.12 – Auditor 30 days 3.1(1.1)(a) Part 6 – Client relationships (except items 6.1 and 6.2) 15 days 3.1(1.1)(b) Item 6.1 – Client assets 30 days 3.1(1.1)(a) Item 6.2 – Conflicts of interest Part 7 – Regulatory action 15 days 3.1(1.1)(b) Part 8 – Legal action 15 days 3.1(1.1)(b) Firms – other notice requirements in NRD format Open/change of business location (other than head office) 15 days 3.2 Form 33-109F3 Cessation of Authority of a registered or permitted individual – Items 1-4 – Item 5 15 days 4.2(2)(a) Form 33-109F1 30 days 4.2(2)(b) Individuals – Form F4 information in NRD format Item 1 – Name 15 days 4.1(1)(b) Form 33-109F5

Policy Statement to Regulation 33-109 June 6, 2022 14 Item 2 – Address (except items 2.1 and 2.2) 15 days Item 2.1 – Current and previous residential address 30 days 4.1(1)(a) Item 2.2 – Mailing address Item 3 –Personal information No update required 4.1(2) Item 4 –Citizenship 30 days 4.1(1)(a) Item 5 – Registration jurisdictions 15 days 4.1(1)(b) Item 6 –Individual categories 15 days Item 7 –Address for service 15 days Item 8 – Proficiency 15 days Item 9 – Location of employment 15 days Item 10 – Reportable activities 30 days Item 11 – Previous employment 30 days 4.1(1)(a) Item 12 – Resignations and terminations 15 days Item 13 – Regulatory disclosure 15 days Item 14 – Criminal disclosure 15 days 4.1(1)(b) Item 15 – Civil disclosure 15 days Item 16 – Financial disclosure 15 days Item 17 – Ownership of securities 15 days Change of F4: registrant position or relationship with sponsoring firm / permitted status 15 days 4.1(4) Form 33-109F2 Review of a permitted individual 15 days after appointment 2.5 Form 33-109F4 or Form 33-109F7, subject to conditions Automatic reinstatement of registration subject to conditions within 90 days of cessation date 2.3(2) Form 33-109F7

Policy Statement to Regulation 33-109 June 6, 2022 15 Appendix B Contact Information for the Regulators and IIROC • Part 1 provides the regulators’ contact information for registrants in all categories, except for those in the jurisdictions and categories listed in Part 2 • Part 2 below, provides IIROC’s contact information in the jurisdictions where IIROC performs registration functions for Approved Persons of investment dealers and, in some cases, for investment dealer firms PART 1 – Regulators’ Contact Information Alberta e-mail: registration@asc.ca fax: (403) 297-4113 Alberta Securities Commission Suite 600, 250–5th St. SW Calgary, AB T2P 0R4 Attention: Registration British Columbia e-mail: registration@bcsc.bc.ca fax: (604) 899-6506 British Columbia Securities Commission P.O. Box 10142, Pacific Centre 701 West Georgia Street Vancouver, BC V7Y 1L2 Attention: Registration Manitoba e-mail: registrationmsc@gov.mb.ca fax: (204) 945-0330 The Manitoba Securities Commission 500-400 St. Mary Avenue Winnipeg, MB R3C 4K5 Attention: Registrations New Brunswick e-mail: nrs@fcnb.ca fax:(506) 658-3059 Financial and Consumer Services Commission of New Brunswick / Commission des services financiers et des services aux consommateurs du Nouveau-Brunswick Suite 300, 85 Charlotte Street Saint John, NB E2L 2J2 Attention: Registration Newfoundland and Labrador e-mail: scon@gov.nl.ca fax: (709) 729-6187 Superintendent of Securities, Service NL Government of Newfoundland and Labrador P.O. Box 8700, 2nd Floor, West Block Confederation Building St. John's, NL A1B 4J6 Attention: Registration Section Northwest Territories e-mail: SecuritiesRegistry@gov.nt.ca fax: (867) 873-0243 Government of the Northwest Territories Department of Justice P.O. Box 1320 Yellowknife, NWT X1A 2L9 Attention: Exemption Review Staff Nova Scotia e-mail: nrs@novascotia.ca fax: (902) 424-4625 Nova Scotia Securities Commission Suite 400, 5251 Duke Street Halifax, NS B3J 1P3 Attention: Registration Nunavut e-mail: CorporateRegistrations@gov.nu.ca fax: (867) 975-6594 Government of Nunavut Department of Justice P.O. Box 1000 Station 570 Iqaluit, NU X0A 0H0 Attention: Superintendent of Securities

Policy Statement to Regulation 33-109 June 6, 2022 16 PART 1 – Regulators’ Contact Information Ontario Telephone: (416) 593-8314 e-mail: registration@osc.gov.on.ca Ontario Securities Commission 22nd Floor 20 Queen Street West Toronto, ON M5H 3S8 Attention: Compliance and Registrant Regulation Prince Edward Island e-mail: ccis@gov.pe.ca fax: (902) 368-5283 Securities Office Department of Community Affairs and Attorney General P.O. Box 2000, 95 Rochford Street Charlottetown, PE C1A 7N8 Attention: Superintendent of Securities Québec e-mail: inscription@lautorite.qc.ca fax : (514) 873-3090 Autorité des marchés financiers Direction de l'encadrement des intermédiaires 800 square Victoria, 22e étage C.P 246, Tour de la Bourse Montréal (Québec) H4Z 1G3 Saskatchewan e-mail: registrationsfsc@gov.sk.ca fax: (306) 787-5871 Financial and Consumer Affairs Authority of Saskatchewan Suite 601 1919 Saskatchewan Drive Regina, SK S4P 4H2 Attention: Registration Yukon e-mail: securities@gov.yk.ca fax: (867) 393-6251 Government of Yukon Office of the Yukon Superintendent of Securities P.O. Box 2703 C-6 Whitehorse, YT Y1A 2C6 Attention: Superintendent of Securities PART 2 Investment Industry Regulatory Organization of Canada Contact Information ** registration of investment dealer firms and their Approved Persons **

• registration of investment dealer Approved Persons * ** Alberta – IIROC ** ** Saskatchewan- IIROC ** e-mail: registration@iiroc.ca fax: (403) 265-4603 #2300, 355- 4th Avenue SW, Calgary, AB T2P 0J1 Attention: Registration department British Columbia – IIROC e-mail: registration@iiroc.ca fax: 604-683-3491 1055 West Georgia Street Suite 2800 – Royal Centre Vancouver, BC V6E 3R5 Attention: Registration department

Policy Statement to Regulation 33-109 June 6, 2022 17 ** Newfoundland and Labrador – IIROC **

• Ontario – IIROC * e-mail: registration@iiroc.ca fax: (416) 364-9177 Suite 1600, 121 King Street West Toronto, ON M5H 3T9 Attention: Registration department
• Québec – IIROC * ** New Brunswick – IIROC ** e-mail: registration@iiroc.ca fax: (514) 878-0797 Organisme canadien de réglementation du commerce des valeurs mobilières 525 Viger Avenue West, Suite 601 Montréal (Québec) H2Z 0B2 Attention: Service des inscriptions

Policy Statement to Regulation 33-109 June 6, 2022 18 Appendix C Reportable Outside Activities Yes No Yes No No Yes No Yes No reporting of the outside activity required For each activity, is the activity outside your sponsoring firm? Category 1 -Is the activity with or for an entity registered under securities or derivatives legislation? Report the outside activity Category 3 -Is the activity raising money for an entity through the issuance of securities/derivatives or promoting the sale of the securities/derivatives? Category 4 - Is the activity a financial or finance-related service? Category 5 - Is the activity a position of influence? Category 2 -Is the activity for an entity that receives compensation (e.g., sales commissions, referral fees) from a firm registered under securities or derivatives legislation?

Policy Statement to Regulation 33-109 June 6, 2022 19 Appendix D Discretionary Exemption for Bulk Transfers of Business Locations and Individuals (1) If a registered firm is acquiring a large number of business locations (for example, as a result of an amalgamation or asset purchase) from one or more other registered firms that are located in the same jurisdiction(s) and registered in the same categories as the acquiring firm, and if a significant number of individuals are associated on NRD with the business locations, the regulator will consider granting an exemption from any or all of the following requirements: (a) to submit a notice regarding the termination of each employment, partner, or agency relationship under section 4.2 of the Regulation; (b) to submit a registration application or a reinstatement notice for each individual seeking to be a registered individual under section 2.2 or 2.3 of the Regulation; (c) to submit a Form 33-109F4 or Form 33-109F7 for each permitted individual under section 2.5 of the Regulation; (d) to notify the regulator of a change to the business location information in Form 33-109F3 under section 3.2 of the Regulation. (2) The exemption application should be submitted by the registered firm that will acquire control of the business locations at the closing of the transaction and should be submitted well in advance of the date (transfer date) on which the business locations will be transferred. It would typically be sufficient if a firm submits the application at least 30 days before the transfer date. An application for this type of exemption should include the following information: (a) the name and NRD number of the registered firm that will acquire control of the business locations; (b) for each registered firm that is transferring control of the business locations; (i) the name and NRD number of the registered firm, (ii) the address and NRD number of each business location that is being transferred from the registered firm named in (b)(i) to the registered firm named in (a), (iii) the date that the business locations and individuals will be transferred to the registered firm named in (a).

Policy Statement to Regulation 33-109 June 6, 2022 20 (3) If the exemption is granted, as soon as practicable after the transfer date, the regulator will instruct the NRD administrator to record on NRD the transfer of the business locations, registered individuals and permitted individuals. (4) Bulk transfers involving firms that are registered in different categories or different jurisdictions may need to take additional steps. Firms involved in such a transaction should contact their principal regulator to discuss what steps are required for the firm to be eligible for a bulk transfer exemption as described above. (5) A firm applying for this type of exemption in more than one jurisdiction should refer to Policy Statement 11-203 respecting Process for Exemption Applications in Multiple Jurisdictions (Décision 2008-PDG-0061, 2008-02-22) for guidance on the form of application and the information required. The firm may set out the information referred to in (2) as follows: A) Registered firm that will acquire the business locations Name: Firm NRD number: B) Registered firm transferring the business locations Name: Firm NRD number: Business locations that will be transferred Address of business location: NRD number of business location: Address of business location: NRD number of business location: (Repeat for each business location as necessary) C) Date that business locations will be transferred: Decision 2014-PDG-0142, 2014-11-14 Bulletin de l’Autorité: 2015-01-08, Vol. 12 n° 01 AMENDMENTS Decision 2017-PDG-0128, 2017-10-25 Bulletin de l’Autorité : 2017-11-30, Vol. 14 n° 47

Policy Statement to Regulation 33-109 June 6, 2022 21 Decision 2022-PDG-0005, 2022-02-09 Bulletin de l’Autorité : 2022-03-17, Vol. 19 n° 10