IAs must now file an annual auditor certificate on client-level advisory/distribution segregation
Non-individual Investment Advisers must obtain an annual auditor certificate confirming compliance with the Regulation 22 client-level segregation rule (a client can't take both advisory and distribution services from the same IA group) — due within 6 months of financial year-end, and folded into the existing compliance audit under Regulation 19(3), not a separate filing.
“The IAs shall maintain on record an annual certificate from an auditor confirming compliance with the client level segregation requirements as specified in Regulation 22 of the IA Regulations. Such annual certificate shall be obtained within 6 months of the end of the financial year and form part of compliance audit, in terms of Regulation 19(3) of the IA Regulations.”
An IA firm that also runs a distribution arm under the same brand must, each year, get its auditor to certify — within 6 months of financial year-end, folded into the regular compliance audit — that no single client is receiving both advisory and distribution services from the group at the same time.
Illustrative scenario written by Northspread — not text from the circular itself.