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CIFO guidance on Trust Beneficiaries


CIFO guidance on Sufficiently Close Relationship of Trust Beneficiaries to a Financial Services Provider to a Trust Introduction

Some complaints referred to CIFO involve investments recommended by a financial services provider [FSP], held in trust. In these cases, the FSP is a service provider to the trust (serving as an investment manager).

The trust provider is also a financial services provider and is, therefore, not an eligible complainant against the respondent FSP under the law governing CIFO’s mandate.

Several trust providers, therefore, asked the CIFO to consider whether.

  • Trust beneficiaries could complain against the FSP providing investment management services to the trust.
  • Are trust beneficiary eligible complainants by virtue of their sufficiently close relationship with the respondent FSP service provider to the trust?


  • Asked the respondent FSP for its views on this matter.


  • CIFO was provided with an extensive written opinion from the respondent FSP’s external counsel.


  • Also asked the trust providers that had requested this decision to provide their views.


  • CIFO received a substantial written response from one trust provider.
  • Two other trust providers submitted emails expressing their high-level views.

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