Using alpha-numeric identifiers for disclosure

Our by-laws permit certain trust depositors (such as lawyers, notaries, brokers/dealers, real estate agents, etc.) who hold funds in trust in the normal course of business, to replace the name and address of beneficiaries with an alpha-numeric code or other identifier, provided they maintain the beneficiary's information on their records.

Who can use alpha-numeric codes or other identifiers in substitution for the name and address of beneficiaries?

Pursuant to the CDIC Joint and Trust Account Disclosure By-law, trustees who may substitute the alpha-numeric or other identifier for the name and address of the beneficiaries include:

  1. the public trustee of a province or a similar public official whose duties involve holding moneys in trust for others;
  2. a federal, provincial or municipal government, or a department or agency thereof;
  3. a solicitor or partnership of solicitors, a law corporation, or a notary or partnership of notaries in the province of Quebec, when they act in that capacity as a trustee of moneys for others;
  4. a person who is acting as a trustee of moneys for others in the course of business and is required by or under a statute to hold the deposit in trust;
  5. a person who is acting as a trustee of moneys for others in the course of business and is subject to the rules of a securities commission, stock exchange or other regulatory or self-regulating organization that audits compliance with those rules; or
  6. a regulated federal or provincial trust company acting in the capacity of a depositor.