A Dealer Member is onboarding a new client, 'Dynamic Ventures Corp'. It is a private Canadian company wholly owned by 'Keystone Capital Inc.', which in turn is owned 60% by Ms. Alvarez and 40% by Mr. Bai. Both are Canadian residents. What action must the Dealer Member take to satisfy beneficial ownership identification requirements for Dynamic Ventures Corp.?

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Accepted Answer

According to CIRO Rule 3204, the Dealer must identify individuals who control 25% or more of the voting rights. By looking through the holding company, Ms. Alvarez (60%) and Mr. Bai (40%) both exceed this threshold and must be identified.

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