1.                   PURPOSE

This document sets out important information concerning our relationship with you and conflicts of interest information. It contains information about HFI, the services that we offer and your account(s) with us. Other important information that you need to know about your relationship with us is contained in other documents that are provided to you as a client, such as the subscription agreement that you complete and the term sheet, offering memorandum or other disclosure documents that you receive when you purchase units of our funds. For HFI clients who receive our investment management services, periodic account statements, reports and updates about changes to information will also be provided to you from time to time.

2.                   AN OVERVIEW OF HFI

HFI is registered as a Portfolio Manager (“PM”), Investment Fund Manager (“IFM“) and Exempt Market Dealer (“EMD”) in the provinces of British Columbia, Alberta, Saskatchewan, Manitoba, and Quebec.

3.                   THE PRODUCTS AND SERVICES WE OFFER

HFI, as an IFM, offers investment management services and creates investment funds for our own clients and investors of other registered adviser firms. The investment funds created, managed, and advised by us are described on our website at www.hoovest.com/funds.

HFI, as a PM, offers investment management services (“discretionary portfolio management services”) to individuals, corporations, trusts, estates, and institutions.

HFI, as an EMD, offers trading services to clients who purchase securities of our funds directly from us or who purchase other securities through us (i.e., not through another registered dealer). As an EMD, HFI is only permitted to trade in securities distributed under a prospectus exemption (for example, to “accredited investors” within the meaning of applicable securities laws) or that are distributed under a prospectus but in transactions for which a prospectus exemption is available but not relied upon. When HFI provides these services, our relationship with our clients will generally not extend beyond the completion of each particular transaction.

For further information, see section 5 “YOUR ACCOUNT”.

4.                   DELIVERY OF RELATIONSHIP DISCLOSURE INFORMATION

This document will be provided to you at the time you open your account(s) with HFI or before we begin providing advice or trading services to you. If there is a significant change to the information contained in this document, we will post the updated version on our website at www.hoovest.com/disclosures.

5.                   YOUR ACCOUNT

5.1          Account agreement documentation

For clients who receive our discretionary portfolio management services, information about the account you have with us will be contained in the know-your-client (KYC) information collection form (“Client Account Form”), “investment management agreement”, “investment policy statement”, or other similar agreement that we enter with you, as well as the periodic account statements and updates about changes to information that will be provided to you from time to time.

For clients who purchase units of our funds or other issuers through HFI’s EMD for a particular transaction, specific information about the account you have with us is contained in the subscription agreement that you complete, the term sheet, offering memorandum or other disclosure documents that you receive. When we provide these services to you, you will have a non-discretionary investment account with us for the purposes of completing a particular transaction. Our relationship with you is limited to the completion of each particular transaction and will not extend beyond the completion of a transaction or otherwise involve an ongoing or continued client relationship. This means that when a transaction is completed and we have provided you with the reporting required in connection with that transaction (see below under sections 5.3 “Account statements” and 5.4 “Trade confirmations”), your account with HFI will be closed and your relationship with HFI as a client will end.

In addition, we will collect information from you referred to as know-your-client (KYC) information (such as information necessary to establish your identity and information regarding your investment needs, financial circumstances, and risk tolerance) which we are required to collect under applicable securities laws can be found in the above documents applicable to your account.

5.2          How securities are registered and held

Securities in your investment account with our discretionary portfolio management service may be held at a client account custodian where it may be a client-name account (where the securities are registered in your name) or a nominee account (where the custodian holds those securities in their name on your behalf). Where no custodian account exists, the securities will be registered in your name.

Securities purchased by you through HFI’s EMD will be registered in your name or another name you direct (but not in our name). If you purchase securities of our funds or other issuers and certificates evidencing those securities are issued, the certificate will be provided to you or the person or company you direct. When you purchase securities of our funds or other issuers and certificates evidencing those securities are not issued, your ownership of the securities will be reflected in the records of the applicable fund or issuer.

5.3          Account statements

We will provide statements to you about your account as follows:

For HFI clients who receive our discretionary portfolio management services, we will provide quarterly statements unless you have requested statements on a monthly basis or if a transaction (other than an automatic transaction) was affected in your account during the preceding month.

For clients who purchase securities of our funds or other issuers through HFI’s EMD for a particular transaction, HFI will send you an account statement within three months of the transaction.

HFI will provide statements to you which will contain:

• information about each transaction conducted for you during the time period covered by the statement;
• if applicable, information about each security held, and the cash balance, in your account at the end of the time period covered by the statement;
• summary of fees paid (annual statements only); and
• performance report (annual statements only).

 

5.4          Trade confirmations

For HFI clients who receive our discretionary portfolio management service, we, or the client account custodian, may deliver trade confirmations where applicable in accordance with our respective policies and regulatory requirement.

Where HFI has acted on your behalf in connection with a purchase or sale of a security, HFI will promptly deliver to you, or if you consent in writing, to a registered adviser acting for you, a written confirmation of the trade. A trade confirmation delivered to you will include certain transaction information such as the quantity and description of the security purchased or sold, the price paid or received by you, the commission, sales charge or any other amount charged, the name of the dealing representative and the settlement date of the transaction.

5.5          Obligation to assess suitability:

HFI’s Client Advisory teams comprises Dealing Representatives, Associate Advising Representatives, or Advising Representatives. We have an obligation to you to assess whether a purchase or sale of a security is suitable for you prior to making a recommendation to or accepting instructions from you. To meet this suitability obligation, we collect KYC information from you at the time you open an account with us and, if applicable, we update this information on a periodic basis. We go through a KYP (know-your-product) process to become knowledgeable about the securities and products that we buy and sell for, or recommend to, you.

The KYC information includes information necessary to establish your identity and information regarding your investment needs, financial circumstances and risk tolerance, and will generally be collected in a questionnaire or other documentation that you complete when you retain us.

These requirements do not apply to clients who are registered firms, Canadian financial institutions, or Schedule III banks, or to clients who qualify as “permitted clients” under applicable securities laws and have waived these requirements in writing.

An explanation of certain terms used in our KYC information collection form (Client Account Form) is as follows:

“investment objectives” refers to your financial or investment goals in relation to your investment portfolio. Knowing your investment objectives helps us determine the types of investments that would be appropriate for your account(s). “Income” means that your objective is for the portfolio to provide a regular stream of cash flow. “Growth” means that your primary objective is to achieve capital appreciation over time over current income. “Balanced” means that your primary objective is a mix of both “Growth” and “Income”.

“investment knowledge” refers to your knowledge and experience about investments and the capital markets generally. “Limited” means that you have little knowledge of the markets and are new to investing. “Fair” means that you have a basic knowledge of the markets and some experience with certain types of investments. “Good” means that you have a good working knowledge of the markets and experience with various types of investments. “Excellent” means that you are very knowledgeable and experienced in all aspects of the markets, including the inherent risks involved with aggressive investment products.

“risk tolerance” refers to the degree of variability in investment returns that you are willing to accept. Factors that will impact your risk tolerance will include the time horizon that you have for your investments, when you may require access to your investment capital, your future earning capacity, and the other assets that you may have.

• A “low” risk tolerance means that you are willing to take very little financial risks to earn investment returns. Generally speaking, someone who has a low risk tolerance is able to tolerate seeing their account decline up to 5% in any given calendar year and accept less than 10% in volatility over any 3-year period.
• A “low-to-medium” risk tolerance means that you are willing to take a moderate amount of financial risks to earn investment returns. Generally speaking, someone who has a low-to-medium risk tolerance is able to tolerate seeing their account decline between 5% – 10% in any given calendar year and accept between 10% – 20% in volatility over any 3-year period.
• A “medium” risk tolerance means that you are willing to take an average amount of risk and would expect to earn average investment returns. Generally speaking, someone who has a medium risk tolerance is able to tolerate seeing their account decline between 10% – 20% in any given calendar year and accept between 20% – 30% in volatility over any 3-year period.
• A “medium-to-high” risk tolerance means that you are willing to take an above-average amount of risk in order to try to earn higher than average returns. Generally speaking, someone who has a medium-to-high risk tolerance is able to tolerate seeing their account decline between 20% – 35% in any given calendar year and accept between 30% – 40% in volatility over any 3-year period.
• An “high” risk tolerance means that you are willing to take a substantially above-average financial risk and would expect to earn substantial investment returns. Generally speaking, someone who has a high risk tolerance is able to tolerate seeing their account decline of over 35% in any given calendar year and accept over 40% in volatility over any 3-year period.

If you have questions regarding these terms or any other terms used in our KYC information collection form or other documents provided to you, please let us know.

5.6          Performance benchmarks:

An investment performance benchmark is a standard against which the performance of your investments are compared. HFI may use investment performance benchmarks to assess the performance of your investments (including your investments in our funds) and to allow you to assess their performance against an index of securities reasonably reflective of the composition of your investment portfolio or the portfolios of the funds in which you hold investments. When comparing your investment returns to the returns of an investment performance benchmark, keep in mind that:

• the composition of your investment portfolio, or the portfolios of the funds in which you hold investments, reflects the investment objectives and strategies you have agreed upon or the investment objectives and strategies of the funds, resulting in the composition of the investment performance benchmark differing; and
• investment performance benchmarks do not generally include charges and other expenses.

Further information about investment performance benchmarks is available upon request.

6.                   OPERATING CHARGES ASSOCIATED WITH YOUR ACCOUNTS

For all clients, HFI does not currently charge clients any amounts in respect of the operation, transfer, or termination of their account(s) with us. These types of charges are referred to as “operating charges”. If we decide to impose any operating charges, we will advise you at the time your account is opened in the documents described above (see section 5 of this document) that are applicable to your account(s).

For HFI clients who receive our discretionary portfolio management services, after your account is opened, we will provide you with at least 60 days written notice before we impose any new or increased operating charges. Note that the investment account custodians do generally charge a transfer fee payable directly by you. However, in most cases, the recipient institution often reimburses you for receiving the transferred assets, although we cannot guarantee all financial institutions do so.

If you invest in securities of our funds, other investment funds, or other pooled investment vehicles, you will indirectly bear the fees and expenses paid by those funds or other vehicles. These fees and expenses will be disclosed in the offering documents or other disclosure documents that you receive. For investment funds created, managed, and advised by us, the management fees are disclosed at www.hoovest.com/funds.

You may also be charged other amounts by third parties, such as custodians, who play a role in relation to your account. You should obtain information from those parties directly.

6.1          Our current list of custodians:

• Aviso Wealth Inc. (Credential Qtrade Securities Inc. and Credential Financial Strategies Inc.)
• Interactive Brokers Canada Inc.
• National Bank Independent Network
• Binance Canada

6.2          Our current list of approved brokers:

• Aviso Wealth Inc. (Credential Qtrade Securities Inc., Northwest & Ethical Investments L.P. and Credential Financial Strategies Inc.)
• Haywood Securities Inc.
• Interactive Brokers Canada Inc.
• National Bank Independent Network

7.                   TRANSACTION CHARGES

For HFI clients who receive our discretionary portfolio management services, unless otherwise stated, we do not currently charge clients commissions, short-term trading fees, redemption charges, or other amounts in connection with the purchase or sale of securities through their accounts with us. These types of charges are referred to as “transaction charges”. If we decide to impose transaction charges, the charges applicable to securities purchased by you will be described in the subscription agreement or other documentation that you complete or receive prior to completion of the transaction and, if applicable, in the periodic account statements that you receive. Notwithstanding the forgoing, certain accounts of discretionary clients may be designated as “excluded accounts” in a client’s investment policy statement. In such cases, the client has agreed for that specific account to be excluded from discretionary account management fees, and thereby, a commission may be earned by us for placing trades on the client’s behalf. Such commissions are disclosed in the relevant offering document or subscription agreement, where applicable. In rare instances, securities in such excluded accounts pay a referral fee to us instead of a commission, or a combination of referral fee and commission. Such fee arrangement will be disclosed to the client and only occurs in equitable scenarios where the fees we earn would be comparable to the fees that the client would pay at another dealer or investment advisor firm.

HFI’s EMD may charge clients a commission on the purchase of securities as disclosed in the offering document of the security.

If you invest in securities of our funds, other investment funds, or other pooled investment vehicles, you will indirectly bear the fees and expenses borne by those funds or other vehicles. These fees and expenses will be disclosed in the offering document or other disclosure documents that you receive.

You may also be charged other amounts by third parties, such as your investment adviser (if your account is managed by an investment advisor firm that is not HFI), dealer, or custodian, who play a role in relation to your account. You should obtain information from those parties directly.

8.                   COMPENSATION PAID TO US

HFI clients who receive discretionary portfolio management services will generally pay us compensation that is based on a percentage of the value of the assets under our management, which may be subject to a minimum fee, or a monthly fixed service fee as agreed to between the client and us in the investment policy statement. We may use our own funds for discretionary accounts, and we will purchase the reduced fee-based class (F Class) of those funds to be comparable to the same fees that someone would pay if the person is a client at another investment advisor firm that uses third-party funds.

HFI may receive certain compensation in relation to the securities or other products that you purchase through your account with us, including a commission based on a percentage of the value of the securities purchased or a management fee, performance fee, or other similar compensation in relation to our role as the IFM or PM of our funds, or for the other services we agree to provide to you in the account agreement documentation we have with you.

9.                   RISKS TO CONSIDER WHEN MAKING AN INVESTMENT DECISION AND OUR SUITABILITY OBLIGATIONS

Securities laws require HFI to provide all clients with a description of risks that you should consider when making an investment decision. This information can be found in the offering document and includes, but is not limited to, the comments below.

For HFI clients who receive discretionary portfolio management services, we will continue to work with you on your overall investment objectives and design and implement a portfolio for you that considers these factors as part of our fiduciary duty to look after the assets we manage for you. You are nonetheless advised to consider these risks as well as part of our ongoing relationship.

For HFI clients transacting through HFI’s EMD, our Dealing Representatives remain obligated to consider suitability of an investment regardless whether we act on a transactional or non-discretionary basis. This may mean that if our Dealing Representative finds a trade to be unsuitable for you, we may be obligated to refuse the trade. The factors set forth below will add to your understanding of investments and risks in helping you make investment decisions that are suitable for you.

You should carefully consider whether an investment is appropriate for you in light of your experience, objectives, financial resources and other relevant circumstances. You should understand the nature of the investment and the extent of your exposure to risk. Depending on the nature of your investment, the type of investment risk will vary. Investment risks include:

Capital risk – the risk that you may lose the money you invest.

Business risk – the risk inherent in the operations of the entity or industry in which you have invested.

Financial risk – the risk associated with the amount of leverage or debt that the entity in which you have invested has used to finance assets.

Currency risk – the risk that currency movements alone may affect the value of your investment if it is held in another currency.

Interest rate risk – the risk that the principal of a debt instrument that you have invested in will increase or decrease as the interest rates in the economy increase or decrease.

Liquidity risk – the risk that your investment may not be readily saleable.

Market risk – the risk that your investment in securities traded on a stock exchange or other public market may be affected by general changes in the market.

Foreign market risk – the risk that foreign investments may experience larger or more frequent price changes in the short term due to different financial, political, and social factors.

Securities purchased through HFI may be referred to as “exempt market securities”. They are called exempt market securities because the issuer is not required to provide you with a prospectus (a document that describes the investment in detail and gives you some legal protections). There will be restrictions on your ability to resell exempt market securities. Exempt market securities are generally regarded as more risky than other securities.

The specific risks associated with an investment in our funds or in other securities purchased from or through us will be described in the applicable offering documents or other disclosure documents under the heading “Risk Factors” or another similar heading.

10.               RISK OF USING BORROWED MONEY TO FINANCE AN INVESTMENT

When you use borrowed money to purchase a security or make other investments, that investment is subject to certain additional risks. You may purchase securities using available cash, or a combination of available cash and borrowed money. If you use available cash to pay for the securities in full, the percentage gain or loss will equal the percentage increase or decrease in the value of the securities. Using borrowed money to purchase securities can magnify the gain or loss on the cash invested. The effect of this is called “leveraging”.

If you are considering borrowing money to purchase securities, you should be aware that a leveraged purchase involves greater risk than a purchase using available cash resources only. To what extent a leveraged purchase involves undue risk is a decision that needs to be made by you and will vary depending on your personal circumstances. In particular, you should be aware of the terms of any loan that is secured by the securities. The lender may require that the amount outstanding on the loan does not rise above an agreed percentage of the market value of the securities. Should this occur, you may be required to pay down the loan or sell the securities so as to return the loan to the agreed percentage relationship. Money is also required to pay interest on the loan. Under these circumstances, investors who leverage their investments are advised to have adequate financial resources available both to pay interest and also to reduce the loan if borrowing arrangements require such a payment.

For HFI clients who receive discretionary portfolio management services, we may use margin, securities lending, derivatives, debt, or other forms of leverage to enhance your returns or manage currency risks within the funds we manage where your account holds units of the funds. We will consider whether the use of leverage is appropriate in each fund, and in rare cases, directly in your account.

11.               FAIR ALLOCATION OF INVESTMENT OPPORTUNITIES

The size and mandate of the various funds and other accounts managed by us differ and the portfolios are not identical. As a consequence, HFI may purchase or sell a security for one account prior to other accounts. This could occur, for example, as a result of the specific investment objectives of the account, different cash resources arising from contributions or withdrawals, or the purchase of a small position to assess the overall investment desirability of a security. If the availability of any particular security is limited and that security is appropriate for the investment objective of one or more other accounts, any purchase of that security will be allocated on an equitable basis in accordance with our fairness in allocation policy.

For HFI clients who receive discretionary portfolio management services, a copy of our “Fair Allocation Policy Disclosure” is included as a schedule in your investment management agreement.

12.               REFERRAL ARRANGEMENTS

HFI may enter into referral arrangements from time to time pursuant to which we refer clients to another entity and receive a fee or another entity refers clients to us for which we pay referral fees. The details of these referral arrangements, including the parties to the referral arrangement, the manner in which the referral fee for referral services is calculated and the party to whom it is paid, will be provided to you in writing when required. All services resulting from a referral arrangement relating to your account which require registration under applicable securities legislation will be provided by the registrant receiving the referral.

13.               CONFLICTS OF INTEREST

HFI seeks to disclose conflicts of interest that arise in the ordinary course of our business. Some of these conflicts of interest are inherent in the business model that we use. We seek to avoid or minimize conflicts of interest where reasonably possible. However, some conflicts of interest cannot be avoided and, although others could be avoided, we have chosen to manage them. We have policies and procedures in place to manage the conflicts of interest that we believe are sufficient to protect the interests of our clients and fulfill our obligations to our clients. A separate “Conflicts of Interest Disclosure Information” document is available on our website at www.hoovest.com/disclosures.

For HFI clients who receive discretionary portfolio management services, our “Conflicts of Interest Disclosure Information” document forms part of a schedule in your investment management agreement. We will update our disclosures on our website as conflicts or potential conflicts arise.

14.               TRADING AND BROKERAGE PRACTICES

HFI uses third party dealers to execute trades on behalf of clients, but we also may have many other relationships with them. It is possible that we may be biased in our selection of dealers based on these relationships, or by certain incentives offered by some dealers. This may result in the commissions paid by our clients being somewhat higher than those that might be charged by different dealers. However, we will endeavour to select dealers to execute trades on behalf of our clients based on their quality of research and ability to execute trades, and will do so in accordance with our broker selection and best execution policy.

For HFI clients who receive discretionary portfolio management services, a copy of our “Disclosure of Broker Selection and Best Execution Policy” is included as a schedule in your investment management agreement.

15.               CANADA’S ANTI-SPAM LEGISLATION

Under Canada’s anti-spam legislation, HFI is required to obtain your consent to send you emails and other electronic messages. We will generally seek this consent from you at the time you open your account. You may withdraw your consent at any time by following the unsubscribe mechanism in the communications that we send to you.

16.               TAX INFORMATION

Under Part XVIII of the Income Tax Act (Canada) and Part XIX of the Income Tax Act (Canada), HFI is required to identify certain clients that have a connection to foreign jurisdictions, and are required to report information about those clients to the Canada Revenue Agency (the “CRA”). The CRA will provide the information to the tax authorities in the relevant foreign jurisdiction if the foreign government has entered into an agreement with Canada for the exchange of financial information. In order to comply with these requirements, we will collect certain information from you at the time you open your account and at other times as needed.

17.               COMPLAINTS AND DISPUTE RESOLUTION

If HFI receives a complaint from you relating to trading or advising activities provided by us or a representative of our firm, we will provide you with a written acknowledgement of the complaint containing the following information:

• a description of our obligation, if any, under National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations to make an independent dispute resolution or mediation service available to you;
• the steps that you are required to take in order for an independent dispute resolution or mediation service to be made available to you; and
• the name of the independent dispute resolution or mediation service that will be made available to you and contact information for the service.

In addition, if HFI decides to reject a complaint or to make an offer to resolve a complaint, we will provide you with written notice of that decision.

HFI will make an independent dispute resolution or mediation service available to you at our expense if:

• after 90 days of our receipt of the complaint, we have not given you written notice of our decision in respect of the complaint and you have notified the independent dispute resolution or mediation service specified by us that you wish to have the complaint considered by the service; or
• within 180 days of your receipt of written notice of our decision in respect of the complaint, you have notified the independent dispute resolution or mediation service specified by us that you wish to have the complaint considered by the service.

There are limitations on your ability to have a complaint resolved at our expense by an independent dispute resolution or mediation service. HFI is only required to follow this procedure if the complaint is received by us within six years of the day when you first knew or reasonably ought to have known of an act or omission that is a cause of or contributed to the complaint. Also, you must agree that, for the purpose of the independent service’s consideration of the complaint, the amount claimed (if any) will be no greater than $350,000.

HFI may follow other procedures in relation to a complaint made by a “permitted client” within the meaning of applicable securities laws that is not an individual.

Further information regarding these matters is attached as Schedule A.

18.               YOUR RELATIONSHIP WITH US

It is important that you actively participate in our relationship. In particular, HFI encourages you to:

• Keep us fully and accurately informed regarding your personal circumstances, and promptly advise us of any change to information that could reasonably result in a change to the types of investments appropriate for you, such as a change to your income, investment objectives, risk tolerance, time horizon, or net worth.
• Review the documentation and other information that we provide to you regarding your account, transactions conducted on your behalf, and the holdings in your portfolio.
• Ask questions of and request information from us to address any questions that you have about your account, transactions conducted on your behalf or the holdings in your portfolio, or your relationship with us or anyone acting on our behalf.

19.               PRIVACY, DATA COLLECTION, USE, AND DISCLOSURE

HFI requires your consent to collect, use, disclose, or retain your personal information. HFI also requires your consent to obtain your credit report. Consent can be express, implied, or given through an authorized representative such as a lawyer, agent, or broker. Express consent may be given orally, in writing, or electronically. Implied consent is obtained when HFI can reasonably infer consent based on your circumstances. Subject to legal, business, or contractual requirements, you can withdraw or refuse your consent to our collection, use or sharing of information at any time upon giving us reasonable notice. However, this withdrawal or refusal may impact the products or level of service that we provide you. Our practices in regard to privacy, data collection, use, and disclosure are disclosed in our privacy and data policy.

For HFI clients who receive discretionary portfolio management services, our “Privacy and Data Policy” forms part of a schedule in your investment management agreement. Our Privacy and Data Policy may be amended from time to time without notice and is disclosed on our website www.hoovest.com/disclosures.

 

 

SCHEDULE A WHAT TO DO IF YOU HAVE A COMPLAINT

Our complaint processes

Filing a complaint with us:

If you have a complaint about our services or a product, contact us at:

Hoovest Financial Inc.

#48421 – Suite 732, 1055 Dunsmuir Street

Vancouver, BC V7X 1A2

Phone: +1 604 229 2788 Email: complaint@hoovest.com

Tell us:

• what went wrong;
• when it happened; and
• what you expect, for example, money back, an apology, account correction.

Help us resolve your complaint sooner •  Make your complaint as soon as possible. •  Reply promptly if we ask you for more information. •  Keep copies of all relevant documents, such as letters, emails and notes of conversations with us.

We will acknowledge your complaint:

We will acknowledge your complaint in writing, as soon as possible, typically within five business days of receiving your complaint. We may ask you to provide clarification or more information to help us resolve your complaint.

We will provide our decision:

We normally provide our decision in writing, within 90 days of receiving a complaint. It will include:

• a summary of the complaint;
• the results of our investigation; and
• our decision to make an offer to resolve the complaint or deny it; and an explanation of our decision.

If our decision is delayed:

If we cannot provide you with our decision within 90 days, we will:

• inform you of the delay;

A word about legal advice You always have the right to go to a lawyer or seek other ways of resolving your dispute at any time. A lawyer can advise you of your options. There are time limits for taking legal action. Delays could limit your options and legal rights later on.

• explain why our decision is delayed; and
• give you a new date for our decision.

You may be eligible for the independent dispute resolution service offered by the Ombudsman for Banking Services and Investments (OBSI).

If you are not satisfied with our decision:

You may be eligible for OBSI’s dispute resolution service.

If you are a Québec resident:

You may consider the free mediation service offered by the Autorité des marchés financiers.

Taking your complaint to OBSI:

You may be eligible for OBSI’s free and independent dispute resolution service if:

• we do not provide our decision within 90 days after you made your complaint; or
• you are not satisfied with our decision.

OBSI can recommend compensation of up to $350,000.

OBSI’s service is available to clients of our firm. This does not restrict your ability to take a complaint to a dispute resolution service of your choosing at your own expense, or to bring an action in court. Keep in mind there are time limits for taking legal action.

Who can use OBSI:

You have the right to use OBSI’s service if:

• your complaint relates to a trading or advising activity of our firm or by one of our representatives;
• you brought your complaint to us within 6 years from the time that you first knew, or ought to have known, about the event that caused the complaint; and
• you file your complaint with OBSI according to its time limits below.

Time limits apply:

• If we do not provide you with our decision within 90 days, you can take your complaint to OBSI any time after the 90-day period has ended.
• If you are not satisfied with our decision, you have up to 180 days after we provide you with our decision to take your complaint to OBSI.

Filing a complaint with OBSI:

Information OBSI needs to help you OBSI can help you best if you promptly provide all relevant information, including: •     your name and contact information •     our firm’s name and contact information •     the names and contact information of any of our representatives who have been involved in your complaint •     details of your complaint •     all relevant documents, including any correspondence and notes of discussions with us

Contact OBSI

Email: ombudsman@obsi.ca

Telephone: 1-888-451-4519 or 416-287-2877 in Toronto

OBSI will investigate:

OBSI works confidentially and in an informal manner.

It is not like going to court, and you do not need a lawyer.

During its investigation, OBSI may interview you and representatives of our firm. We are required to cooperate in OBSI’s investigations.

OBSI will provide its recommendations:

Once OBSI has completed its investigation, it will provide its recommendations to you and us. OBSI’s recommendations are not binding on you or us.

OBSI can recommend compensation of up to $350,000. If your claim is higher, you will have to agree to that limit on any compensation you seek through OBSI. If you want to recover more than $350,000, you may want to consider another option, such as legal action, to resolve your complaint.

For more information about OBSI, visit www.obsi.ca.