Last updated on September 19, 2022
About this Disclosure
We believe that successful long-term relationships are built on a foundation of trust and transparency, where both parties clearly understand their roles, obligations, and expectations. In that spirit, and to meet the requirements of securities legislation to make certain disclosures to you, we provide this relationship disclosure information. Not all information may apply to your personal circumstances or your relationship with WealthBar Financial Services Inc., doing business as CI Direct Investing (“CI Direct Investing”).
In this disclosure, we refer to CI Directing Investing, as “we”, “us”, “our”, or “CI Direct Investing”.
Along with the Managed Account Agreement (“MAA” or "Agreement") you enter into with us when you open an account, this disclosure describes your relationship with us. By accepting the Agreement and maintaining an account with us, you conﬁrm that you have received this disclosure, understand its contents, and acknowledge your consent to both the Agreement and the matters outlined in this disclosure.
If you have any questions related to the contents of this document, please contact us at 1-877-310-1088 or via email at [email protected].
CI Direct Investing provides financial planning, investment services, and financial products. We are a registered portfolio manager under the securities legislation in all provinces and territories in Canada.
CI Direct Investing is a subsidiary of CI Financial Corp (CIX) and an affiliate of CI Investments Inc., which is one of Canada's largest investment management companies. CI Global Asset Management (CI GAM) is a registered business name of CI Investments Inc. CIX is a publicly traded corporation whose shares are traded on the Toronto Stock Exchange (TSX: CIX) and the New York Stock Exchange (NYSE:CIXX).
Our head office is located at #900 – 625 Howe Street, Vancouver, BC, V6C 2T6. You can reach us also by telephone: 1-877-310-1088; by fax: 1-888-373-7674 or by email: [email protected].
Products and Services
CI Direct Investing takes a unique approach to wealth management through our convenient online platform and high standard of client care. We provide discretionary investment advisory and digital financial planning services. In addition to the investment products available through our platform, CI Direct Investing also offers access to no fee high interest savings accounts operated by third party financial institutions.
We use a team approach to provide you with advice and service. When you need to contact us, you can use an online messaging service through our online platform or email [email protected]. You can book a call with members of our portfolio management, financial advice, or customer service teams on request.
Members of our teams may contact you to assist with requests like account opening, transfers, and other account maintenance. This ensures you get the timeliest service possible.
CI Direct Investing acts as a portfolio manager for your separately managed account, which means we make investment decisions for you based on your investment strategies and objectives and the information about your personal and financial circumstances you provide us as part of our collection of "KYC" information (described below). Discretionary investment authority for the assets under our management is governed by your Agreement with us.
Our investment strategy is based on the view that your asset mix primarily determines portfolio performance and includes diversified asset classes in portfolios to maximize returns at different levels of risk. Our portfolios primarily contain Exchange Traded Funds (“ETFs”) and commission-free mutual funds. We use passively indexed funds along with selective actively managed investment funds. We may also invest your money in cash equivalents or other securities that we deem appropriate.
We offer a variety of portfolios tailored to your needs and preferences, including low-cost portfolios of ETFs, portfolios with access to private investments, socially responsible impact investing portfolios, and more. We also provide optional thematic investment exposure in your portfolio.
The liquidity of our portfolios is generally not restricted. You will be informed of any securities held in your portfolio with limited liquidity.
We offer portfolios managed directly by CI Direct Investing and by sub advisors, including portfolios managed by our affiliate, CI Investments Inc. (“CI GAM”). Unless otherwise presented to you during account opening, the construction of the portfolios managed by CI Direct Investing considers all available securities (i.e. non-CI GAM funds, as well as CI GAM funds). In these portfolios, investment funds managed by CI GAM may be used in these portfolios where we consider them to be in the best interest of our clients.
The CI Direct Investing account opening process will indicate which portfolios are managed by CI Direct Investing and which are managed by CI GAM or another sub advisor. You can view a current list of our portfolios and who manages them at our Portfolio Disclosure page.
In portfolios managed by CI GAM, CI GAM will consider the various investment funds managed by CI GAM and will generally only include investment funds not managed by CI GAM where it considers that CI GAM does not have a suitable investment fund for that portfolio. Generally, CI GAM will not consider other investment funds that may have characteristics, such as cost structure, or past performance, similar or superior to the securities managed by CI GAM. More information on how we address the conflicts of interest inherent in offering CI GAM portfolios and CI GAM investment funds can be found in our Conflicts of Interest Disclosure.
Investment decisions on the appropriate portfolio for your account, as well as for the underlying securities in portfolios managed by CI Direct Investing are made by CI Direct Investing’s portfolio managers, who are registered advising representatives with the applicable securities regulators. We make portfolio recommendations and manage your account to meet your individual needs based on the “know your client” (“KYC”) information you provide during the online account opening process (“Application”). A portfolio manager may contact you for additional information, and you can speak to a portfolio manager about your investments.
You can create a personalized financial plan and discuss your financial situation and goals with a financial advisor or financial planner employed by CI Direct Investing. Our financial advisors and financial planners have a relevant credential (such as a Certified Financial Planner® professional or Qualified Associate Financial Planner™). These services are covered by the management fees you pay us.
You may work directly with a financial advisor or financial planner (“Representative”) not employed by us and you may agree to pay them for the financial planning services they will provide you. If your Representative suggests that you use our platform for your investment needs, we will facilitate your payment of the fees you agree to pay to your Representative or his/her sponsoring firm by withdrawing this amount out of your CI Direct Investing Account. If this is the case, on account opening with us, we will ask you to confirm the fees you have agreed to pay and you will enter into a Service Fee Agreement with your Representative.
Hold on Deposits
Deposits to your CI Direct Investing account may be held for up to 30 days before they can be withdrawn in order to prevent fraud and identity theft. Since we are an investment management firm not meant for short term trading, our clients do not typically withdraw funds within this window.
Cash from new deposits, transfers in, and investment income is usually invested within one week. If you have a portfolio composed of ETFs, cash will typically be invested within a few days. If you have a portfolio composed of mutual funds or private investments, cash will typically be invested once weekly, on Fridays. In some cases, it can take up to one month for cash in your account to be invested.
However, there may be a few reasons why your cash isn’t invested:
- Accounts must have a minimum balance of $1,000 to be invested.
- Accounts will not be traded if your portfolio choice has not been confirmed by a portfolio manager. If you requested a different portfolio than we recommended, a portfolio manager may need your explicit confirmation before we invest your account.
- Small cash balances of less than $100 or less than 0.5% of the account value may not be invested.
If your cash isn’t invested and you don’t know why, please contact us.
Know Your Client (“KYC”) Information
We act as a portfolio manager on your behalf and are required to obtain certain KYC information from you before executing any transactions so that we can determine whether investments are suitable for your situation in relation to your investment objectives, risk profile and other personal and financial circumstances. We are required to put your interests first, ahead of our own interests and any other competing considerations, when making any recommendations or taking any investment action in your account.
KYC information includes details:
- to establish your identity
- to establish whether you are an insider of a reporting issuer
- concerning your investment needs and objectives
- to understand your personal circumstances
- to establish your investment time horizon
- to note your investment knowledge
- to assess your financial circumstances, and
- to determine your risk profile (willingness and ability to take on risk)
We may consider additional information, where relevant to your particular circumstance.
You provide KYC information when you complete the online Application, and maintain KYC information through our online platform. The KYC information that you have provided to us at the time of your account opening, “Application Snapshot,” is available in the Documents section of the CI Direct Investing platform.
It is important that you provide us with accurate KYC information and let us know about any changes to your KYC information. This includes letting us know if your circumstances change or if any of the information you previously provided needs to be updated. This could include changes to your address, marital status, employment, income, attitude about risk, or investment assets or debt. If there are changes, we will review the new information, assess the investment recommendation and, if necessary, make changes to your portfolio. We will connect with you on a periodic basis to confirm there are no changes to your information or circumstances so that we can assess that your portfolio remains suitable for your needs and objectives.
CI Direct Investing is required under applicable securities regulations to ensure each investment recommendation or investment action is suitable based on the information you provide to us, including that the recommendation or investment action puts your interests first. This requirement applies both to transactions recommended by us and transactions proposed by you.
We must take reasonable steps to confirm that, before we make a recommendation to buy or sell a security for your managed account, it is suitable for you based on the KYC information you provided and puts your interests first. A portfolio manager must assess and agree with the suitability of any transaction based on the KYC information you provided.
Our Help Centre provides some helpful definitions of the KYC terms that will be used in collecting information about your circumstances and that will allow us to make a suitability determination for you.
Trusted Contact Person
We encourage you to provide us with the name and contact information of a trusted contact person, who should be an individual with whom you are comfortable allowing us to discuss your financial or personal circumstances, in specific circumstances. We may contact your trusted contact person and/or disclose information about you or your account to your trusted contact person:
(i) if we are concerned that you are being exploited financially
(ii) if we are concerned about your mental capacity as it relates to your ability to make decisions involving financial matters
(iii) to obtain the name and contact information of your legal representative, if any; and
(iv) to obtain your contact information if we cannot get in touch with you.
When you provide us with a name of a trusted contact person, you confirm to us that you have the consent of that person to provide us with their name and contact information and that the person knows you are naming them as your trusted contact. As with your other account information, it is important to keep this information current. Learn more about naming a trusted contact person.
CI Direct Investing provides you with a summary of your account(s) in accordance with regulatory requirements, including a monthly statement with information about your investments including original cost, market value, performance, fees, and transactions.
You can access your account information, account statements, and tax documents at any time through our online platform. Account information available includes fees, current holdings, activities, and portfolio values as of the last date of valuation. Account statements are provided through the online platform monthly, and we will notify you when they are made available each month. Any tax documents related to your account(s) are provided through the online platform and we will notify you as each tax document is made available.
You should regularly review all account information, portfolio holdings, and performance. Please contact us if you have any questions or concerns about your client reporting. Please review your statements and notify us of any discrepancies within 45 days of its distribution.
We charge a management fee regardless of your account performance. Management fees are based on a blended annual rate, calculated daily, and deducted from your account each month in arrears. The management fee we charge reduces the return of your account over time. We determine your blended annual rate based on the value of all of your accounts according to the pricing tiers in our fee schedule (Schedule B of the Agreement). We calculate your monthly management fee by applying the daily equivalent of your blended annual rate to your daily balances. Charging a monthly management fee based on account balances instead of other pricing structures, like earning commissions on investments, supports our commitment to providing you with objective advice.
Visit our Help Centre for the most recent management fee schedule.
Our management fee covers our investment advisory and financial planning services, as well as the following costs incurred by your account:
- custodial fees
- trading fees
- account administration fees
- registration fees (for TFSAs and RRSP, Spousal RRSP, LIRA, RIF and LIF plans subject to account minimums), and
- deregistration fees (for deregistration of registered plans such as TFSAs, RRSPs, etc.)
We will not introduce any new charges or fees unless we provide you with at least 60 days prior written notice. Any such changes may be further restricted under the Agreement, or by securities rules and regulations.
Costs of Holding Investment Funds - Understanding Management Expense Ratios (MER) and Trading Expense Ratios (TER)
You indirectly pay fees or expenses related to management, brokerage, legal, accounting, and custody, of ETFs or mutual funds held in your portfolio. These fees and expenses are described as the management expense ratio (MER) and the trading expense ratio (TER) and are the fees paid to the fund managers and expenses associated with operating the funds held in your portfolio. The MER and TER are not fees and expenses deducted from your account and are instead reflected in the value of the investments in your portfolio. Both ratios are expressed as a percentage of fund assets and the fees and expenses are not billed to you directly. The MER and TER do affect you because the fees and expenses paid by a fund reduces the fund’s return and the overall performance of your account.
We calculate the aggregate MER of the investments in your portfolio using a weighted average of the MERs of the investments in your portfolio. This is shown on your account statements on our online platform.
You should note that every dollar taken out to cover fees of any type is one dollar less to invest in your account. The impact of these fees compound over time as a deduction to the overall value of your account and over longer periods of time, this impact increases. We can answer any questions you may have about the fees and expenses of each fund in which you invest.
Foreign Exchange Fees
You may be charged up to a thirty-five (35) basis point (0.35%) foreign exchange fee by the custodian of your account on currency conversion if we need to buy or sell foreign currency to trade securities in your account. We primarily use Canadian denominated investments, reducing the likelihood of a foreign currency conversion in your account.
Operating Charges, Transaction Charges and Compensation
Any operating charges, transaction charges or other compensation, and any other expenses you may be subject to, are set out in your Agreement.
CI Direct Investing and its employees do not collect commissions from the investments held in your account. The only compensation we receive is the management fee you agree to pay us. (see the Management Fee section). We do not, for example, receive trailing commissions from the fund managers of the investment funds in which you invest.
If we receive any commissions as a result of investment products held in your name, they will be credited to your account on a pro-rata basis, based on the holdings in the account and the time the security was held during the billing period. This credit will be reflected on your statement.
Risks of Investing
As a CI Direct Investing client, you benefit from the expertise of portfolio managers who are dedicated to selecting investments for your specific portfolio. Visit our Help Centre for a summary of investment risks that may be associated with your portfolio.
Leverage Disclosure Statement
Using borrowed money to finance the purchase of securities involves greater risk than using cash resources only. If you borrow money to purchase securities, your responsibility to repay the loan and pay interest as required by its terms remains the same even if the value of the securities purchased declines.
We do not lend you nor help you borrow money for investing. We do not adjust our recommendation if you are using borrowed funds to invest. If you wish to discuss this additional risk with us, please reach out to one of our portfolio managers.
Where Your Assets Are Held
CI Direct Investing does not take physical custody of your assets or accounts; all of your assets and accounts are held in your name ("client name") by an external custodian or carrying broker. We do not have access to your assets held by your custodian. This is the primary benefit of having a third-party custodian and minimizes the risk of loss. You have provided us with the authority to instruct custodians to buy and sell securities in your account(s) and debit your account management fees.
In selecting a custodian, we considered such factors as:
- ease and cost of trade execution
- the size, financial stability, and strength of the custodians
- the reduction of risk of loss to the client assets through the selection of more than one custodian, and
- the laws and regulations to which each custodian is subject
We believe the selection of large, financially sound, and regulated custodians substantially reduces the risk of loss or misappropriation of client assets and is in the best interest of our clients.
CI Direct Investing has a written agreement in place with each custodian which outlines the roles and obligations of CI Direct Investing and the custodian. In addition to holding your assets, the custodian is responsible for providing services including acting as a dealer to trade securities as directed by CI Direct Investing, completing tax reporting, providing confirmations and statements, and deducting our management fee.
We have selected one or more of the following companies to act as your custodian: CI Investment Services Inc. (an affiliate of CI Direct Investing), Credential Qtrade Securities Inc., and National Bank Independent Network. All of our custodians are Canadian custodians under applicable securities laws and members of the Canadian Investor Protection Fund (“CIPF”), which provides protection for your accounts in case of the custodians’ insolvency for up to $1 million per account type. Visit CIPF to learn more.
We monitor our custodial arrangements and may make changes to or appoint additional custodians should we determine it is in the best interest of our clients.
CI Direct Investing may place a temporary hold on the purchase or sale of a security on your behalf or on the withdrawal or transfer of cash or securities from your account, where we reasonably believe that you might have an illness, impairment, disability or aging-process limitation that places you at risk of financial exploitation, and we believe that you are, or may be exploited financially, or if we believe you do not have the mental capacity to make decisions involving financial matters. If we place a temporary hold on your account in either of these situations, a notice of the temporary hold and the reasons for the temporary hold will be provided to you as soon as possible after placing the temporary hold. Unless the hold is revoked, a notice of the decision to continue the hold and the reasons for that decision will be provided to you within 30 days of placing the temporary hold, and within every subsequent 30-day period. We may also contact your trusted contact person, if designated, in these circumstances.
CI Direct Investing has a business continuity plan to help us to continue to serve you where there is a business interruption owing to an unforeseen event (e.g., power outage, earthquake, fire, flood, etc.). We test this plan annually.
Conflicts of Interest
A conflict of interest is any circumstance where the interests of a client and those of CI Direct Investing or individuals acting on our behalf are inconsistent or divergent. We take reasonable steps to identify and respond to material conﬂicts of interest and conflicts that are reasonably foreseeable. Conflicts of interest may include conflicts between:
- you as our client and CI Direct Investing
- you and other CI Direct Investing clients
- CI Direct Investing and our related and associated companies and issuers
CI Direct Investing is committed to ensuring that your interests always have precedence. We seek to ensure effective management of any situation that could give rise to a conflict of interest. We seek to manage conflicts of interest in your best interest.
We respond to conflicts of interest in a fair and transparent manner consistent with the best interests of our clients using three methods:
- control, and
Avoiding Conflicts of Interest
We avoid conflicts that are prohibited by law as well as conflicts that cannot be responded to reasonably with controls or disclosures.
Controlling Conflicts of Interest
We have established policies and procedures to control material conflicts of interest, such as the design of our organizational structure and lines of reporting, physical separation of different business functions, and limiting the internal exchange of information.
Disclosing Conflicts of Interest
CI Direct Investing will provide you with information about any conflicts of interest that may reasonably affect the services we provide at the time of account opening and in certain situations before investing your account. Disclosure will be provided in a timely manner so that you have a reasonable amount of time to assess the conflict.
Please view our Conflicts of Interest Disclosure.
Fair Allocation Trading Policy
CI Direct Investing has in place a fairness policy (the "Policy"), which establishes the procedures for the fair treatment of all clients of CI Direct Investing, with respect to the allocation of investment opportunities.
CI Direct Investing manages client accounts in accordance with specified investment models.
CI Direct Investing will allocate investment opportunities that are suitable for client accounts. In determining the suitability of each investment opportunity to a client account, consideration will be given to a number of factors, which include but are not limited to:
- the client's stated investment objectives and strategies;
- investment merits; the client account's existing portfolio composition;
- the client account's existing portfolio composition; and,
- the target allocations of the models.
When an investment opportunity is suitable for two or more client accounts, CI Direct Investing will allocate such an investment opportunity on a pro rata basis. Each account involved will receive a percentage of the executed portion of the order based upon such account's percentage participation in the entire order. This procedure applies to all accounts participating in the trade falling under the same trading deals. Calculating the average price of all executions taken, as well as the expenses incurred pursuant to the particular order, will determine the security selling or purchase price, and the transaction costs incurred upon the trade. There may be circumstances where the automatic pro rata apportionment will be inappropriate. Should such a circumstance arise, an allocation will be determined by CI Direct Investing on a fair and reasonable basis.
Client accounts, which are managed in accordance to a model portfolio, will maintain the investment composition of the applicable model. CI Direct Investing will group similar client accounts based on the client's investment objectives, and strategies to be managed in line with similar models. CI Direct Investing reviews and approves all allocations.
The Policy applies to all client accounts managed by CI Direct Investing and is continuously monitored, reviewed, and updated on a periodic basis.
Performance Benchmarks and How to Use Them
We do not provide benchmark comparisons. You should speak with a portfolio manager if you have any questions about the performance of your portfolio or which benchmark(s) might be appropriate for you to use to assess the performance of your account.
You may assess the performance of your investments by comparing them to an investment performance benchmark. Benchmarks show the performance over time of a select group of securities. There are many different benchmarks. When choosing a benchmark, you should pick one that reflects your investments. For example, the S&P/TSX Composite Index follows the share prices of the largest companies listed on the Toronto Stock Exchange. This index would be a good benchmark for assessing performance of a Canadian equity fund that invests only in large Canadian companies. It would be a poor benchmark if investments are diversified in other products, sectors, or geographic areas.
We are committed to respecting and protecting the privacy and confidentiality of the information you have entrusted with us. Our Privacy Notice outlines how we collect, use, disclose, store, and safeguard your personal information. Our Privacy Notice is available on our website.
Complaint Handling Process
We are committed to providing you with a high level of service. Should you have a complaint related to your account, contact the Chief Compliance Officer, CI Direct Investing by mail at #900 – 625 Howe Street, Vancouver, BC, V6C 2T6; by telephone by calling 1-800-792-9355; or by emailing [email protected]. In filing a complaint, you should detail what went wrong, when it happened, and what your expectations are.
We will acknowledge receipt of a complaint formally within five business days of its receipt. As soon as practically possible, or within 90 days of receiving a complaint, we will provide a written assessment detailing the results of its investigation, how we have or propose to remedy the situation (or confirmation of no issue) and an explanation of our position and decision. We will endeavour to resolve the matter as quickly as possible and to your satisfaction. Recognizing that investors may not be satisfied with our response or remediation, independent dispute resolution services are available free of charge.
If you are not satisfied, you may seek independent dispute resolution services from the Ombudsman for Banking Services and Investments (OBSI) or from the Autorité des Marchés Financiers if you live in Quebec. You may make a complaint to OBSI after you submitted your complaint to us, at either of the following times:
- If our Compliance Department has not responded to your complaint within 90 days of the date you complained, or;
- After our Compliance Department has responded to your complaint and you are not satisfied with the response. Please note that you have 180 calendar days to bring your complaint to OBSI after receiving our response.
OBSI provides an independent and impartial process for the investigation and resolution of complaints about the provision of financial services to clients. OBSI can make a nonbinding recommendation that we compensate you (up to $350,000) if it determines that you have been treated unfairly, taking into account the criteria of good financial services and business practice, relevant codes of practice or conduct, industry regulation and the law. The OBSI process is free of charge and is confidential. OBSI can be contacted:
- By telephone in Toronto at (416) 287-2877, or toll free at 1-888-451-4519
- By e-mail at [email protected]
Legal Assistance: You may consider retaining a lawyer to assist with the complaint or taking other actions. You should be aware that there are legal time limits for taking civil action. A lawyer can advise you of your options and recourses. Once the applicable limitation period expires, you may lose rights to pursue some claims.
Manitoba, New Brunswick and Saskatchewan: Securities regulatory authorities in these provinces have the power to, in appropriate cases, order that a person or company that has contravened securities laws in their province pay compensation to a claimant. The claimant is then able to enforce such an order as if it were a judgment of the superior court in that province. For more information, please visit:
New Brunswick: www.nbsc-cvmnb.ca
Residents of Québec: If you are not satisfied with the outcome or with the examination of a complaint, the Autorité des marchés financiers (“AMF”) can examine your complaint and may provide dispute resolution services. If you think you are a victim of fraud, fraudulent tactics or embezzlement, you can contact the AMF to see if you meet the eligibility to submit a claim to the Fonds d’indemnisation des services financiers (“Financial Services Compensation Fund”). An indemnity up to $200,000 can be payable through monies accumulated in the fund for an eligible claim. For more information: Contact the AMF by telephone at (418) 525-0337 (in Québec), or toll free at 1-877-525-0337 or visit www.lautorite.qc.ca