When formulating your comment, please keep in mind the following:

• implications of 'handling' versus 'holding' of client funds
• re-approval process of current LMD registrants
• proficiency requirements and exemptions for experience
• margin and credit restrictions

What problems or benefits would the above requirements pose for your organization and why? Based on the CSA mandate to harmonize, streamline and modernize registration requirements, what alternatives would you propose and why?