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Part One

The Product Review

The product review is the firm's answer to the question an alert raises: does our assessment and approval of this product still hold?

1
The Workflow
Six stages from an open alert to a closed review

In the KYP HubWhere alerts come from: Material Change. When a change should reopen KYP: Material Change: When to Reopen a KYP Assessment.

1
Triage
Confirm the alert is real, not a data error. Assign a reviewer and due date by severity.
2
Gather
Pull the source documents, the current assessment, exposure and alert history.
3
Assess
Does the original assessment of structure, features, risks and costs still hold?
4
Decide
Record one of the defined outcomes, with rationale and any conditions.
5
Communicate
Notify advisors who hold or offer the product, and supervision, with the updated assessment.
6
Close
Update the product file, set any settle window or review date, and close the alert.

Triage matters more than it looks. A meaningful share of alerts in any monitoring system come from data problems - a stale field, a corporate action recorded wrongly. Confirming the alert is real before a reviewer spends time on it saves effort, and routing data errors to the data owner rather than closing them as "no action" keeps the record honest.

The assessment is against the product's own file. The question isn't whether the change is good or bad in general, but whether the firm's documented understanding of this product - its strategy, risks, costs, parties and features - is still accurate. If it isn't, the file needs updating whatever the decision.

SeverityReviewerDecided ByIllustrative Timeframe
CriticalProduct analystProduct committeeOpened within 1 business day; decided within 5
ImportantProduct analystProduct owner, escalating to committee if the decision is anything other than maintainDecided within 10 business days
WatchProduct ownerProduct owner, at the next scheduled reviewBy next scheduled review
2
The Decision
Five outcomes, defined in advance so every reviewer means the same thing

A review should end in one of a small set of defined outcomes. Letting reviewers write free-text conclusions produces decisions no one can aggregate, compare or supervise. The five below cover most situations.

OutcomeWhat It MeansWhat Advisors Must Do
MaintainThe assessment still holds; the product stays on the shelf unchangedNote the change and review the updated file if one was issued
Maintain with watchThe assessment holds for now, but the product gets closer monitoring and a set review dateReview the updated file; expect a further decision by the review date
RestrictThe product stays available with conditions, such as limiting it to advisors with specific training or requiring pre-approvalOffer it only within the conditions
SuspendNo new purchases or recommendations until a defined condition is met; existing holdings stay under monitoringStop recommending new purchases
RemoveThe product leaves the shelf; a wind-down plan appliesFollow the wind-down plan

These map onto the responses Canadian regulators describe: revisiting the firm's approval, implementing additional controls around the sale of the security, and, where corrective action is limited by illiquidity or redemption restrictions, halting new sales.[1] Removal is covered in the first guide, Product Approval.

3
The Review Record
What a completed review should show, with a filled-in example

Canadian regulators expect approval records to show "meaningful consideration" of the key elements assessed and support for why the decision was appropriate.[1] A review that re-confirms an approval is held to the same standard. The example below uses a hypothetical fund.

Product Review Record: Example
Hypothetical
Alert
MF-11 Portfolio Manager Change (v1.4), Critical. Detected from the fund's amendment filing.
Product
Example Canadian Equity Fund, all series. Held by 42 advisors across 1,180 accounts.
What changed
The lead portfolio manager of eleven years retired. A co-manager who has been on the team for four years becomes lead. Mandate, fees and holdings unchanged.
Sources
Amendment filing; manager's announcement; call with the fund company; current holdings; the new lead's track record on the fund and a prior mandate.
Assessment
The investment process is team-based and documented; the new lead co-managed the fund for four years with no change in style. The original assessment's description of process and risk still holds. The description of people is out of date.
Decision
Maintain with watch. Product file updated. Review date in six months to confirm style and holdings remain consistent with the mandate.
Decided by
Product Committee, day 4. Reviewer and approver named.
Communicated
Notice and updated product summary sent to all 42 advisors and supervision on day 4; acknowledgement required within 10 business days.

What makes this record useful is that the rationale is specific. "Reviewed - no concerns" would record that a review happened; it wouldn't show that anyone considered what changed.

Part Two

The Advisor Response

While the firm reviews the product, each advisor who offers it has their own obligation: to keep their understanding of the product current. SEC staff have said financial professionals "cannot satisfy their own care obligations by solely relying on the efforts of others at their firm,"[2] and Canadian rules give each registered individual a separate duty to understand what they recommend.[3]

1
Six Steps
What an advisor does when a product alert or change notice arrives
  1. Read the alert. What changed, when, and how severe the firm has rated it.
  2. Understand the change. Open the source - the filing, notice or data - rather than relying on the one-line summary.
  3. Check the product's status. Has the firm decided yet? Is the product maintained, restricted or suspended?
  4. Update their understanding. Read the updated product file or summary, and complete any acknowledgement or training the firm requires. Canadian regulators cite firm practices such as requiring individuals to acknowledge key product information, and re-examination when a significant change affects a security.[1]
  5. Act within the status. Stop recommending a suspended product; stay within any restriction.
  6. Record and close. A short note on what they reviewed and understood, then close their copy of the alert.
SeverityAdvisor ActionIllustrative Timeframe
CriticalRead immediately; stop new recommendations until the firm decides if the alert says so; acknowledge the decisionRead within 1 business day; acknowledge within 10
ImportantRead, review the change and record a noteWithin 10 business days
WatchAwareness only; reviewed in the advisor's regular routineNext routine review
2
The Advisor Note
Short, specific and about the product

An advisor's note on a product alert doesn't need to be long. It needs to show that the advisor understood what changed. Compare:

WeakStrong
"Reviewed. No concerns.""Read amendment and firm review. Lead PM retired; co-manager of four years now lead. Process and mandate unchanged per firm review. Product maintained with watch, review in six months. Acknowledged updated summary."
"Fee change noted.""Management fee on Series A up 0.10% from next month per filing. MER impact about 0.11%. Series F unaffected. Reviewed updated cost section of product file."

The fourth guide, Advisor Due Diligence, covers product notes in more depth.

Part Three

Putting It Together

The two tracks only work if they meet at the right points. A worked example shows where.

1
A Worked Example
One Critical alert, followed through both tracks

Using the hypothetical portfolio manager change from the review record above:

DayFirm TrackAdvisor Track
0Engine detects the change from the amendment filing; Critical alert raised and routed to the product committee, 42 advisors and supervisionAdvisors receive the alert: "Review in progress - decision expected within 5 business days"
1Triage confirms the alert is valid; analyst assignedAdvisors read the alert and the filing
2 - 3Analyst gathers sources, calls the fund company, drafts the reviewNo action required; product remains available pending decision
4Committee decides: maintain with watch; product file updated; notice sentAdvisors receive the decision and updated summary
5 - 14Supervision tracks acknowledgementsAdvisors read the summary, acknowledge, and record a note
14Unacknowledged advisors escalated to their supervisorsRemaining acknowledgements completed
Month 6Scheduled watch review; decision recordedAdvisors notified of the outcome

The handoffs are on days 0, 4 and 14: the alert reaches advisors with an expected decision date, the decision reaches them with the updated file, and supervision closes the loop on who has confirmed they understood it. The fifth guide, Supervising a KYP Program, covers that oversight in detail.

2
Responsibilities and Written Process
Who does what, and what the firm writes down
What the Firm Needs to Do
  • Triage every alert. Confirm it is valid before review; route data errors to the data owner.
  • Assign and time-box. A named reviewer and a due date for every alert, set by severity.
  • Assess against the file. Test the change against the product's documented assessment.
  • Decide from defined outcomes. Maintain, maintain with watch, restrict, suspend or remove.
  • Record meaningful consideration. Sources, specific rationale, decision-maker and date.[1]
  • Communicate the decision. To every advisor who holds or offers the product, with the updated file.
  • Close the loop. Track acknowledgements and escalate the ones that are overdue.
What the Individual Advisor Needs to Do
  • Read every alert. Within the timeframe for its severity.
  • Go to the source. Read the filing or notice, not just the summary.
  • Respect the status. Act within any restriction or suspension immediately.
  • Update their understanding. Review the updated file and complete required acknowledgements or training.
  • Write a specific note. What changed and what they reviewed.
  • Close their alert. So supervision can see it was handled.
Example: Written Process for Alert Review
Illustrative
1
Triage. Every alert is triaged within one business day of being raised. Alerts caused by data errors are routed to the data owner and recorded as such, not closed as reviewed.
2
Assignment. Each valid alert is assigned a named reviewer and a due date according to the severity matrix.
3
Assessment. The reviewer assesses the change against the product's current KYP file using the firm's review record template, citing the sources reviewed.
4
Decision. Every review ends in one of five outcomes: maintain, maintain with watch, restrict, suspend or remove. Critical alerts, and any outcome other than maintain, are decided by the Product Committee.
5
Communication. Decisions on Critical and Important alerts are communicated to every registered individual who holds or offers the product, and to supervision, within one business day, with the updated product summary.
6
Advisor response. Advisors read Critical alerts within one business day, act within any change in product status immediately, and acknowledge decisions within ten business days with a note on what they reviewed.
7
Escalation. Overdue reviews are escalated to the Committee chair; overdue advisor acknowledgements to the advisor's supervisor.
8
Records. Alerts, triage results, review records, decisions, notifications, acknowledgements and advisor notes are retained and linked to the product.
Five Questions to Test Alert Handling
  1. Are data-error alerts separated from real alerts, rather than closed as "no action"?
  2. Does every review end in one of a small set of defined outcomes?
  3. Would a review record show what changed and why the decision was made, not just that a review happened?
  4. Do advisors receive the decision and updated file, not only the original alert?
  5. Can the firm show which advisors acknowledged each decision, and what happened to those who didn't?
A note on scope: This guide describes practical approaches to handling product alerts. It covers product-level review and advisors' understanding of products; client-level follow-up is outside its scope. It is general information, not legal or compliance advice. The workflow, outcomes, timeframes, review record, advisor notes, worked example and written process are illustrations, not prescribed requirements; the example fund is hypothetical.
References
  1. Joint CSA/CIRO Staff Notice 31-368, Client Focused Reforms: Review of Registrants' Know Your Client, Know Your Product and Suitability Determination Practices and Additional Guidance, December 10, 2025. Registered individuals' KYP and firm practices, pp.13-14; approval, pp.15-16; responses to significant changes, pp.17-18. Source document (PDF)
  2. U.S. Securities and Exchange Commission, Staff of the Divisions of Trading and Markets and Investment Management. Staff Bulletin: Standards of Conduct for Broker-Dealers and Investment Advisers - Care Obligations, April 30, 2023. Source document
  3. CIRO. Investment Dealer and Partially Consolidated Rules, Rule 3302 (Know-Your-Product). Source document (PDF)