National Instrument 31-103 Client Relationship Model Phase 2 (CRM2) is a disclosure-based regulation designed to enhance the advisor-client relationship by imposing a higher fiduciary duty on advisors. Investors are provided with greater transparency regarding the fees they pay to advisors, the services they are being charged for and investment performance reporting.
CRM2 impacts to client engagement
Pre-Sale Disclosure
Advisors are required to disclose related costs to clients prior to all trades.
Trade Confirmations
Trade confirms must include all transaction costs including debt security cost and deferred sales charges.
Annual Reporting
Compensation cost and performance reports must be provided to all accounts annually.
How InvestorCOM helps firms with CRM2
Document Disclosure & Recordkeeping | Client Reporting | E-migration
Manage recordkeeping and demonstrate disclosure
Dealers use the InvestorPOS add-on to ComplianceExpress to provide pre-trade disclosure of all charges (including DSC and trailing commissions) paid by clients when buying or selling a security.
Fund Facts are used by advisors to disclose mutual fund fees. ComplianceExpress captures a record of this disclosure and generates CRM2 fee disclosure reports at any time.
- Search Fund Facts from 120+ fund companies.
- Deliver electronically, in-person or by print/mail.
- Track when documentation was sent, received and opened.

Design and deliver compliant communications
Our Client Communication Management (CCM) platform makes it easy to deliver client documents – financial statements, trade confirmations, tax slips, cost and compensation reports, and performance reports – across digital and print channels.
The platform is complemented by our expertise in document design and e-migration strategy development and execution.
