Question: The Staff Position published on the Israel Securities Authority site, entitled "Summary of the Project to Improve the Investment Advice Process for the Customer", which related to the obligations of documentation according to the Regulations for Investment Advice, Investment Marketing and Investment Portfolio Management (Record of Transactions and Record of Advisory Activity), 5768 – 2007 (hereafter: "Conversation Documentation Regulations") which specified the date on which an investment conversation should be recorded and what is considered to be documentation "near the time of the advice", stated that in exceptional cases, and under certain conditions specified there, documentation that occurs no later than 10:00 on the following day after the advice was given will be considered to be "near the time of the advice". Is the current period, in which the economy is under the effect of the Corona crisis and there is an exceptional load on licensees, considered to be "exceptional" with respect to the published Staff Position?
Answer: Yes. The current period, in which the economy is suffering from the Corona crisis, is to be considered highly exceptional and therefore the documentation of an investment advice conversation that is created no later than two weeks after the advice is given, and in a manner that is acceptable according to what is stated in the Staff Position for Improving the Investment Process, will be considered to be documentation carried out "near the time of the advice" with respect to article 7 of the Conversation Documentation Regulations.
Moreover, if the licensee who provided the advice is forced to enter quarantine according to the directives of the Ministry of Health and is prevented from accessing the system that would allow him to complete the documentation within two weeks after the advice was given, the period will be extended for a number of days after the end of the quarantine period, according to the decision of the entity responsible for the advice which approved the late documentation.
 See Link (Hebrew Version)