For matters which require Client Identification, the recording of the client’s employer information is addressed in Rule 16. Please ensure that the employer address and phone number of a client are documented without exception. This includes public employers such as hospitals and universities. This also includes documenting the employer information of tradespeople. For example, indicating “carpenter” or “driller in an oilfield” is not adequate. If the client is retired, self-employed, a homemaker, or unemployed, this needs to be documented as part of the ‘Know Your Client’ obligations.

Additionally, for matters which require verification of client identification, recording the origin of the source of funds is addressed in our Practice Resources. When a client is paying funds into the trust fund, such as a down payment, the economic activity that produced the funds must be recorded. For example, recording the source of funds as “savings from employment”, “sale of asset”, “inheritance”, etc., would be satisfactory if this information matches what is known of the customer profile. Professional judgement is required to determine if further questions are needed, and any risk assessment taken would also have to be recorded.

Violations of the record keeping requirements of Rule 16 may be subject to an administrative penalty. Please refer to our Practice Resources, or contact Jenn Friesen, Trust Auditor at jfriesen@lsnl.ca if you have further questions.

Posted: 28 January 2026