GMP Capital Trust – Bill 198 (C-SOX) compliance

Successfully implemented a project to comply with initial requirements of Canadian Securities Administrators Multilateral Instrument 52-109 relating to the evaluation of the design effectiveness of internal control over financial reporting.

	GMP Capital Trust an income trust listed on the TSX, carries on business through several entities and is a leading independent Canadian investment dealer and full-service investment firm focused on investment banking and institutional equities for corporate, private and institutional investors.
Client:	GMP Capital Trust
Industry:	Compliance
Project:	Bill 198 (C-SOX) compliance
Services:	Risk management/controls consulting including project management
Objective:	Comply with initial requirements of Canadian Securities Administrators Multilateral Instrument 52-109 relating to the evaluation of the design effectiveness of internal control over financial reporting
Solution:	A two-phased approach was used: Planning and scoping: A risk-based, top down approach was used to determine the scope of process/controls documentation and control design evaluation for each significant account, disclosure and process at each significant business unit, focusing on significant and high-risk areas. Mapped financial statements and note disclosures to underlying business processes and IT applications. Documenting and Evaluating Controls Design Effectiveness : Consisted of information gathering, documentation of in-scope processes (via narratives, flowcharts, internal control matrices and walkthroughs), identification of financial reporting risks and relevant financial statement assertions for significant accounts and disclosures, evaluation of the design effectiveness of controls and development of action plans for remediating identified deficiencies.
Result:	Notwithstanding a very tight deadline, successfully met all compliance requirements.